Japan JCII Embarks upon FCM Product Registration Service Starting from Apr. 1

To deploy Japan's FCM positive list system, on June 1, 2020 the Japan Chemical Innovation and Inspection Institute (JCII)^[1] set up the Food Contact Material Safety Center (hereinafter “safety center”) by incorporating responsibility of Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA), Japan Hygienic PVC Association (JHPA) and Japan Hygienic Association of Vinylidene Chloride (JHAVDC). This newly-established organization takes charge of the coordination between government and enterprises, and aims to guarantee the compliance in the whole FCM supply chain. Detailed services of safety center are as following:

Collect information as well as conduct investigations on the safety of food contact material products;
Confirm and authenticate the compliance of FCM products;
Provide assistance in adding new substances to FCM positive list;
Develop FCM safety research;
Cooperate and communicate with relevant institutions;

Starting from April 1^st this year, the safety center will begin to accept applications for a FCM compliance certificate, which indicates the food contact material conforms to the voluntary standards (voluntary standards consist of FCM positive list and the Standard of Hygienic Testing Methods).

FCM compliance certificate
Certificate type		Example
Ingredient	The ingredients included in the positive list conform to the voluntary standards	Synthetic resins (pellet) Additives Colorants
Raw material	Container and packaging raw materials made by substances included in the positive list conform to the voluntary standards	Synthetic resins (film and sheet)and other materials
Product	Containers and packaging used for production, usage and selling, which are made by ingredients or raw materials mentioned above, conform to the voluntary standards.	Packaging bags lunch boxes food trays, etc.
Test requirements: Different tests shall be conducted based on the different product categories, but all product tests shall comply with Article 18 of the Food Sanitation Law.
Inspection system: After delivering the FCM compliance certificate, check whether the registered product meets the voluntary standards every year.

It is noteworthy that the safety center adopts membership system. That is, only registered enterprises, organizations and individuals are eligible for various services offered by Safety Center.

Membership types:

Regular member	Enterprises that manufacture and sell the food container and packaging raw materials
	Enterprises that manufacture, process and sell food container and packaging
	Food manufacturing, processing, and sales enterprises that involves food container and packaging
Associate member	Industry groups, testing institutions, certification agencies, training institutions, consulting companies, etc. related to FCM safety
Individual	University teachers
Individual	Researchers from public institutions, etc.
Organization	Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA)
	Japan Hygienic PVC Association (JHPA)
	Japan Hygienic Association of Vinylidene Chloride (JHAVDC)

Membership benefits :

Have the product reviewed based on the latest positive list and get the certificate;
Submit industry suggestions to the government via safety center;
Acquire timely interpretation regarding positive list mechanism;
Obtain various information and materials related to FCM positive lists;
Have the priority to participate in various seminars held by the safety center;
Could access the consultation service related to positive list system and the whole supply chain management;
Could access the assistance and consultation service related to new FCM substance registration;

All enterprises, organizations, and individuals could apply for the membership of safety center. However, the applicants are required to have agency or branch in Japan, and should submit all application materials in Japanese. The agency or branch shall be responsible for all issues, including payment of the membership fee and annual fee, etc.