In our previous article, we outlined Japan’s introduction of a Positive List (PL) system for food contact materials (FCMs) under the Food Sanitation Act. As the official enforcement date of June 1, 2025 passed, Japan’s Consumer Affairs Agency (CAA) released crucial updates clarifying final procedures, exemptions, and a phased transition period.
Table of Contents
Positive List: Finalized Substances and Recent Additions
As covered previously, Japan’s Positive List framework restricts FCMs to only approved base polymers and additives. The list currently includes 21 base polymers and 827 initial additives, with 13 new substances added through 2024 amendments (serial nos. 828–840).
New CAA Q&A and Official Manual
To help businesses comply, the CAA published a detailed Q&A document on May 9, 2025, providing clarifications on which products fall within the scope of the regulation, along with side-by-side comparisons of the draft and finalized provisions, and practical explanations for exemptions and migration limits
Guidelines for Adding or Revising Substances
On May 28, 2025, the CAA released updated guidelines (In Japanese language) outlining clear procedures for adding new substances or revising standards for monomers and additives. These guidelines specify:
- Required technical documentation
- Application forms and evaluation timelines
- Administrative steps for stakeholder submissions
Five-Year Transition Period
Importantly, the CAA has confirmed a five-year transition period, giving businesses until June 1, 2030 to sell or use their stock of food contact materials manufactured or imported before the enforcement date. This transitional measure ensures a practical shift for manufacturers and importers that need more time to adapt.
Conclusion
Japan’s Positive List system is now fully in force. With the final Q&A, updated amendment guidelines, and the confirmed five-year transition period, stakeholders have a clear compliance roadmap. Companies must ensure that any FCMs placed on the Japanese market from June 1, 2025 onward comply with the Positive List or qualify for an exemption; otherwise, they risk non-compliance.
