Japan Updates Food Containers and Packaging Safety Standards

Japan has amended safety standards for food containers and packaging to restrict the use of first-class specific chemicals and introduce new testing protocols.

Compliance Answer: Japan’s Amended Safety Standards for Food Containers and Packaging

Japan has recently amended its safety standards for food apparatus, containers, and packaging (ACP) under the Food Sanitation Act (Act No. 233 of 1947). The amendments introduce restrictions on certain chemicals, revise testing protocols, and establish a Positive List system for synthetic resins. Below is a structured breakdown of the key changes, their legal basis, and compliance requirements.

1. Legal Framework and Authority

The amendments are issued under Article 18, Paragraph (1) of the Food Sanitation Act, which empowers the Prime Minister to establish specifications and standards for ACP or their raw materials after consulting the Food Safety Standards Council. The revisions are codified in the Specifications and Standards for Foods, Food Additives, Etc. (Public Notice No. 370 of 1959), overseen by the Consumer Affairs Agency (CAA)^{1, 2}.

2. Key Amendments and Compliance Requirements

A. Restrictions on Chemical Substances

1. Prohibition of Class I Specified Chemical Substances
   • The use of "Class I specified chemical substances" (defined in Article 2, Paragraph (2) of the Act on the Regulation of Manufacture and Evaluation of Chemical Substances (Act No. 117 of 1973)) as raw materials for ACP is prohibited¹.
   • Compliance Action: Manufacturers must verify that no raw materials contain these substances. No transitional period is specified for this prohibition.

1. Positive List System for Synthetic Resins
   • A Positive List system is established for synthetic resins used in ACP. Only substances listed on the Positive List or those approved via an individual application process may be used¹.
   • Process:
   • Submit an application to the Prime Minister for safety review.
   • The Food Safety Commission of Japan provides opinions during the review.
   • Approved substances are publicly announced¹.
   • Compliance Action: Businesses must ensure all synthetic resins in ACP comply with the Positive List or obtain individual approval.

B. Revised Testing Protocols

1. Deleted Tests

The following tests are removed from Chapter III, Section B of the Public Notice²:

• Xylene Solubility Substance Test
• Strength Test
• Heavy Metals Limit Test (Material Test)
• Arsenic Limit Test (Material Test)
• n-Hexane Extract Test

1. New Overall Migration Test
   • The Overall Migration Test is introduced to measure the total amount of substances migrating from ACP into food simulants².
   • Test Procedure:
1. Place 200–300 mL of test solution in a pre-weighed evaporating dish (platinum, quartz, or heat-resistant glass).
2. For heptane (food simulant), concentrate the solution under reduced pressure, transfer to the dish, and evaporate to dryness.
3. Dry the residue at 105°C for 2 hours, cool in a desiccator, and weigh.
4. Calculate migration using the formula:

“` Overall migration (mg/cm²) = /<sup>2</sup> “` Where:

• `a` = weight of residue (mg)
• `b` = blank value (mg)².
• Compliance Action: Businesses must adopt this test for synthetic-resin ACP unless individual specifications apply.

1. Revised Test Solution Preparation
   • Methods for preparing test solutions (e.g., evaporation residue, bisphenol A) are consolidated into Section B-12 (renumbered from B-15)².
   • Compliance Action: Update laboratory protocols to align with the new preparation methods.

C. Material-Specific Specifications

1. Synthetic Resins
   • Overall migration limits are set in Section D, Item 2 ("Migration Specifications") for synthetic-resin ACP².
   • Exemption: ACP with individual specifications are not subject to these limits.
   • Compliance Action: Test synthetic-resin ACP for overall migration unless exempt.

1. Deleted Specifications

The following specifications are removed²:

• Strength tests for containers/packaging sterilized by autoclaving (excluding cans/bottles).
• Specifications for soft drink containers (excluding fruit juice).
• Material specifications for cups in vending machines selling pasteurized fermented milk drinks.
• Specifications for containers/packaging used for milk and milk products.
• Material specifications for food vending machines and their containers.

D. Reagents and Test Solutions

• Obsolete reagents and reference materials are deleted from Section C².
• Compliance Action: Update reagent inventories and testing manuals.

3. Transitional Measures and Deadlines

*Transitional period until June 1, 2030 for deleted specifications (e.g., strength tests, milk product containers)².

4. Summary Answer

Japan’s amendments to the Specifications and Standards for Foods, Food Additives, Etc. under the Food Sanitation Act introduce three critical changes:

1. Chemical Restrictions: Prohibition of Class I specified chemical substances and a Positive List system for synthetic resins, requiring immediate compliance¹.
2. Testing Revisions: Replacement of five legacy tests (e.g., n-Hexane Extract Test) with the Overall Migration Test, effective June 1, 2025, and updated test solution preparation methods².
3. Material-Specific Updates: Removal of outdated specifications (e.g., for milk containers) with a transitional period until June 1, 2030².

Businesses must audit raw materials, update testing protocols, and ensure compliance with the Positive List or individual approvals. The CAA enforces these standards, with the amended Public Notice available on its website^{1, 2}.

Sources

1. ↩ WTO SPS notification 26-02406 — Japan https://members.wto.org/crnattachments/2026/SPS/JPN/26_02406_00_e.pdf
2. ↩ WTO SPS notification 26-02407 — Japan https://members.wto.org/crnattachments/2026/SPS/JPN/26_02407_00_e.pdf