The Food Hygiene Standards Review Division of Japan's Consumer Affairs Agency recently announced a public consultation on the Draft Review Procedures for the Content of Substances in Utensils and Container Packaging Raw Materials and Related Safety with a deadline for submissions set for May 23, 2025. Comments can be submitted online via the e-Government comprehensive portal (e-Gov) at https://search.e-gov.go.jp/servlet/Public or mailed to the Food Hygiene Standards Review Division at the Consumer Affairs Agency. The draft aims to enhance the safety management system for food contact materials and is expected to be officially released and implemented within 2025.
Background and Key Content of the Draft
This revision is based on the Food Sanitation Law and the Standards for Food, Additives, etc. It primarily targets the positive list system for food utensils and container packaging, introducing a new system for the publication of substances individually reviewed for safety. This system was approved by the Food Hygiene Standards Council on December 16, 2024, and the specific implementation procedures were passed on March 27, 2025. Key points of the draft include:
Applicable Objects and Review Process
- Scope: Involves the review of permissible content or leachate levels of substances contained in utensils and container packaging raw materials (excluding chemical reaction products) as specified in the Standards.
- Safety Review: Developers or their representatives can submit applications to the Prime Minister, including data on substance names, content, and safety assessment materials. The review, conducted by the Food Safety Commission, will be publicized on the Consumer Affairs Agency's official website if no health risks are confirmed.
Dynamic Reevaluation Mechanism
If new scientific evidence or risk concerns are identified, the Prime Minister will initiate a reevaluation, and based on the results, decide whether to revise or revoke the original review conclusion.
Industry Impact and Compliance Recommendations
This revision marks a further strengthening of Japan's lifecycle regulation of food contact materials. The new system will expedite the approval and public disclosure of safe substances, but substances that fail the review may face market access restrictions. Relevant enterprises should actively participate in the public consultation to ensure smooth regulatory transition and pay attention to the requirements of the review process, preparing compliance materials in advance.
Further Information
