Food Contact

How to Comply with Food Contact Regulations in Japan

Little Pro on 2017-08-07

In Japan, the Ministry of Health, Labor, and Welfare (MHLW) has established specifications for various food contact materials and their raw materials. Japan is also developing a positive list of substances or materials that are permitted for use in manufacturing food contact materials or articles. In addition, various industry associations such as JHOSPA and JPA have set voluntary standards for different types of food contact materials. Those voluntary industry standards are well respected in Japan. In this article, we will show you how to comply with those MHLW specifications and voluntary industry food contact standards, and how to access those specifications and download the postive lists.

Definition of Utensils and Food Containers and Packaging

In Japan, food utensils, containers and packaging are regulated under the Food Sanitation Law. The Food Sanitation Law prohibits the sales of utensils and food container/packaging that contain any toxic or harmful substances. The definition of utensils and food packaging container is listed as follows:

  • Utensils: Tableware, kitchen utensils, and other machines, implements, and other articles which are used for collecting, producing, processing, cooking, storing, transporting, displaying, delivering, or consuming food or food additives and which come into direct contact with food or food additives.
  • Containers and packaging: Articles which contain or wrap food or food additives and are offered “as is” when delivering food or food additives.

MHLW Specifications for FCMs

MHLW has set 3 different types of specifications for food packaging materials and containers:

  • general specifications that apply to all food utensils and food packaging materials;
  • material-specific specifications and standards;
  • specifications applied for some end-use applications that need special consideration;

Those specifications include requirements on migration testing that are aimed at ensuring that finished food contact materials meet various specifications, e.g., heavy metal content and total non-volatile extractives. More info can be found below:

Category Description

General specification


  • General specifications for apparatus, containers and packaging, and their materials:
  • For example: Any part of a food utensil, container, or packaging that will directly touch food must NOT be made or repaired using the metal containing more than 0.1 % of lead or 5 % or more of antimony.


Material-specific specification


  • Synthetic-resin apparatus, containers, or packaging (including 14 types of resins such as  PVC, PEC, etc)
  • Rubber apparatus, containers, or packaging
  • Metal cans (excluding those containing dried foods (except oil & fat and high-fat food products));

Specifications for some end-use applications


  • Containers/packaging used for retort pouch foods
  • Containers/packaging used for soft drinks (glass, metal, synthetic resins, etc.)
  • Apparatus used for manufacturing frozen confections 
  • Automatic food vending machines (limited to those vending machines in which the food touches the machine parts directly), and the containers used to sell the food through these vending machines
  • Carrying apparatus or containers/packaging for soft drink concentrates stored in automatic vending machines to sell food in cups, or full automatic soft drink cooking machines

Note: To download above specifications (in English), please click here.

Voluntary Industry Food Contact Standards

In Japan, trade associations also play a key role in food contact legislation compliance. The Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA), the Japan Hygienic PVC Association (JHPA), the Japan Hygienic Association of Vinylidene Chloride (JHAVDC), and the Japan Paper Association (JPA) have all established voluntary industry for their food contact materials. Those standards are so well respected that customers often require a supplier to have its product certified by the appropriate trade association before a purchase can be made.

Association Description




  • JHOSPA's voluntary standards consists of a positive list of raw materials (synthetic resins, additives, and coloring materials) that can be used safely for food utensils, containers and packaging materials and the Standard Methods of Analysis that defines specifications for each resin.
  • JHOSPA also issues a certificate of compliance for a food contact material upon regular members’request if the material is conformed to the voluntary standards.
  • Companies must join JHOSPA as members to access voluntary standards, request a certificate of compliance or get a new substance onto JHOSPA’s positive list by filing a petition.
  •




  • Voluntary standard “Self specifications on food hygiene of Polyvinyl-chloride resin products” ( JHP Recommendations , 14th Revision) includes a positive list of substances that can be used for producing food contact PVC. 
  • JHPA can also issue a certificate of confirmation upon members' request.
  • Companies need to join JHPA to access the voluntary standard or request a certificate of confirmation.
  •




  • Maintains a positive list of substances that can be used for manufacturing food contact PVDC.
  • Companies need to join JHAVDC to access the voluntary standard or request a certificate of confirmation.
  •




  • Voluntary Standard of Paper and Paperboard Intended for Use in Food Contact sets limits on heavy metals and other harmful substances in food contact use paper.
  • Maintains a list of positive list of substances used to make paper pulp and base paper [Ref].
  • Companies need to join JPA to access the voluntary standard or request a certificate of confirmation.
  •

Positive List of Food Contact Substances in Japan

Japan is currently reforming its food contact legislation. The following changes are expected. 

  • A national positive list system will be set up for synthetic resins. This proposed listing will be based on the voluntary positive lists established by JHOSPAJHPA and JHADVC. [Download the postive lists]
  • Information sharing between business operators will be required;
  • GMP will be required for the manufacturers of food utensils, containers and packaging materials.

Please subscribe to our newsletter to receive updates about new articles and tutorials. 


Having Questions?

We do not provide consultancy services. If you have questions or need any help, please contact our sponsor. You may also find an expert in CSP business directory below. If you are a consultant, you may get yourself listed in CSP business directory (free) or sponsor this page to leave your contact info on this page..

 Tags: Topics - Food ContactFood Contact Regulations