Supply Chains, Food and Beverage, Manufacturing (excludes F&B):
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Summary
Japan has introduced new rules that come into effect on 1 June 2025 for food containers and packaging. The changes mean a shift to a “positive list” for synthetic materials that can be included in food containers, packaging, and equipment put up for sale in Japan. This report provides information on these changes, as well as where more information can be found.
Report
The positive list requirement was introduced in the Food Sanitation Law in 2018, to come into effect in 2020, with five years to develop the positive list and fully implement by 1 June 2025. The positive list sets out what synthetic materials Japan considers safe for food container and packaging purposes. The positive list and the approval process for new materials is highly technical and targeted at the packaging industry. The positive list is administered by the Consumer Affairs Agency (CAA). Last year responsibility for food safety standards (including food packaging) was transferred from Japan’s Ministry of Health, Labor and Welfare (MHLW) to CAA.
Items (equipment, container, or packaging) imported into Japan before 31 May 2025, which are same as those imported before 1 June 2020, can be sold etc after 1 June 2025.
Equipment, containers, or packaging imported into Japan after 1 June 2025, including packaged food products, need to meet the positive list requirements (i.e. be listed in Appendix 1 of the ordinance). Japan has been frequently updating the positive list to add new materials. We understand that the positive list accommodates the majority of packaging on the market prior to 1 June 2020.
The current version of the positive list is available on the CAA website at this link(external link) (in Japanese, some of the documents listed on this page are both in Japanese and English). An English Q+A on the rule changes can be found at this link(external link).
Our advice to New Zealand exporters is to make sure that you hold the specifications for your synthetic packaging materials and are able to provide this information to your trade customers and importers in Japan to demonstrate compliance with the new positive list requirement.
If exporters are experiencing any issues with these new regulations we would welcome any questions to exports@mfat.govt.nz.
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