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On July 29, 2020, the Japanese Ministry of Health, Labor and Welfare (MHLW) released a notice [1] to detail document requirements for expanding the positive list for food contact materials (FCMs).
Earlier on April 28 this year, the MHLW published the announcement No. 196 stating that the positive list system will become effective on June 1, 2020 and a 5-year grace period is given (see ChemLinked news [2]). However, it admitted that the positive list is less-than-perfect and many more substances are to be included. Along with the aforementioned notice, the latest version proposal (including base polymers [3] and additives [4]) of the positive list is made public, in which those in greyed boxes are proposed to be added to the positive list in the future.
According to the notice, for businesses and individuals who wish to add any existing substance (a substance which has been manufactured or distributed in or exported to Japan before May 31, 2020), they can submit a proposal using a table given and a document to confirm its use before the implementation date. For base polymers, minor monomers and additives, there are variations in their corresponding tables, but the confirmation documents are of an identical format.
Where businesses and individuals wish to add any new substance (a substance which has not been manufactured or distributed in or exported to Japan before May 31, 2020), they can submit their proposals following previous notices as well as the Guideline for Assessment of the Effect of Food on Human Health Regarding Food Utensils, Containers and Packaging which was published by the Food Safety Commission of Japan in 2019.
The notice also provided that businesses can apply for modification of information concerning any listed substance by using relevant documents given therein.
