In 2020, Japan officially implemented the Positive List system for food contact materials, marking an important first step towards more effective regulation of food contact material.
On 30 May 2025, Japan Government further refine the regulatory framework by issuing a Cabinet Office Notification No.95. The notification amends the Part 3 (which is related to food contact materials) of the Ministry of Health, Labor and Welfare (MHLW) Notification No. 370 of 1959.
The main purpose of the change is to establish the regulatory framework into a system of the positive list (Clause A, which regulates the manufacturing process) and the “negative list” (i.e. Clause D, material-specific standards, which regulates the residue substances in final products).
Below shows the highlights of the amendments imposed by the Notification No.95
- Strengthen the requirements on plastic material – introduce the overall migration requirements (<0.1 mg/cm2), and optimize the test condition for evaporation residue tests;
- Rewrite clause E ( which are specifications for application-specific implements, containers, and packaging) – removing strength test for container and packaging for food sterilized by pressure and heat; while move requirements for drink and milk container/ packaging into the material-specific standards (clause D), and incorporate their test methods into clause B (General testing methods for containers and packaging);
Following shows the summary of testing requirements for different types of food contact materials
The amendment has come into effective, while the amendments on the test requirements for plastic material will come into effective on 1 June 2026.
| Materials | Total lead and total cadmium | Heavy metals as lead | Evaporation residue/ overall migration | Consumption of KMnO4 | Others |
| Glass, ceramic and enamel | Leachable cadmium and lead | ||||
| Phenolic, urea, and melamine resins | x | x | x | Phenol and formaldehyde | |
| Formaldehyde resins | x | x | x | x | Formaldehyde |
| Polyvinyl chloride resin | x | x | x | x | Dibutyltin, Tricresyl phosphates, and vinyl chloride monomer |
| Polyethylene and polypropylene resins | x | x | x | x | – |
| Polystyrene resin | x | x | x | x | Volatile compounds |
| Vinylidene chloride resin | x | x | x | x | Barium and vinylidene chloride monomer |
| Polyethylene terephthalate resin | x | x | x | x | Antimony and germanium |
| Polymethyl methacrylate resin | x | x | x | x | Methyl methacrylate |
| Polyamide resin | x | x | x | x | Caprolactam |
| Polymethylpentene resin | x | x | x | x | – |
| Polycarbonate resin | x | x | x | x | Bisphenol A, Diphenyl carbonate, and amines |
| Polyvinyl alcohol resin | x | x | x | x | – |
| Polylactic acid resin | x | x | x | x | Lactic acid |
| Polyethylene naphthalate resin | x | x | x | x | Germanium |
| Other plastic resins | x | x | x | – | |
| Rubber materials | x | x | x | Mercaptoimidazoline, Phenol, formaldehyde, zinc | |
| Metal cans | x | x | Arsenic, phenol, formaldehyde, epichlorohydrin, and vinyl chloride monomer |
The amendment has come into effective, while the amendments on the test requirements for plastic material will come into effective on 1 June 2026.
https://www.cmatesting.org/wp-content/uploads/2026/01/EN.pdf
