On 28 May 2025, Japan’s Consumer Affairs Agency (CAA) released updated guidelines relating to Food-Contact Materials (FCMs) under the Food Sanitation Act. The CAA published the guidelines on its official portal. This time, the CAA has revised the procedures for:
Appendix 1 of the Standards for Food, Additives, etc for substances to be added or revised.
The Monomer Notification, which lists allowable monomers and processing agents in food-contact materials.
These updates replace the 2020 guidelines and aligns with the end of the Positive List (PL) transitional period on 31 May 2025. The new guidelines are mandatory from 1 June 2025.
Previous Update in May 2020
The CAA previously revised the guidelines for FCMs in May 2020.
Key Insights from the Standards:
1. Two Types of Revisions:
Appendix 1: For substances expected to be widely used.
Monomer Notification: For additions or changes to monomers and treatment agents.
2. Procedure:
Advance consultation with the Consumer Affairs Agency is required.
Submit official forms (Form 1 or 2) with supporting documents.
Safety and migration data must follow Japan's Food Safety Commission 2019 Guidelines.
A withdrawal form (Form 3) is provided if needed.
3. Required Documents:
Substance name, structure, safety data, usage scope, migration test results, and global regulatory status.