Food Utensils and Containers/Packaging — Food Sanitation Act Checks for Imported Food
Interlink編集部What Are Food Contact Materials and Packaging?
Food contact materials and packaging refer to tableware, cooking utensils, food containers, packaging materials, and similar items that directly or indirectly contact food. While these are not food products themselves, they are used in applications involving food contact, so confirmation under the Food Sanitation Act may be required upon import.
In actual logistics practice, what matters is not whether the product name is listed as "general goods," "kitchenware," "promotional items," "store fixtures," or "machine parts," but whether the product is used for food contact purposes. Items such as plates, cups, lunch boxes, storage containers, packaging bags, and contact parts of food manufacturing machinery may be subject to confirmation under the Food Sanitation Act even if they are not classified as food by name.
When importing food contact materials or packaging for sale or business use, they may fall under the scope of Food Import Notification requirements. Importers, customs brokers, and freight forwarders need to check not only the product name but also food contact usage, contact surfaces, materials, usage temperature, conditions of use, test reports, and manufacturer information.
Scope Covered in This Article
Food contact materials and packaging are governed by multiple regulations, including the Food Sanitation Act, food import notifications, the positive list system, material-specific standards, and labeling requirements. This article focuses on the initial scope for judgment in import practice and refers detailed discussions of specialized systems to related articles.
| Topic | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basic Concept of Food Contact Materials and Packaging | Explains why tableware, cooking utensils, containers, and packaging materials that contact food become an issue under the Food Sanitation Act. | The overall regulatory framework of the Food Sanitation Act is covered in detail in "What Is the Food Sanitation Act?" |
| Relationship with Food Import Notification | Explains the possibility that imports for sale or business purposes may require notification. | Preparation of notification forms, supporting documents, and quarantine office inspection procedures are addressed in "Food Import Notification Forms." |
| Positive List System | Explains that when synthetic resins are used on food contact surfaces, it is important to confirm raw materials, additives, and usage conditions. | Details of target substances, transitional measures, and compliance confirmation are covered in "Positive List System for Food Contact Materials and Packaging." |
| Material-Specific Confirmation | Organizes the differing confirmation criteria for synthetic resins, ceramics, glass, metals, paper, rubber, silicone, etc. | Test methods and standard values by individual material type are explained in specialized articles on each material. |
| Boundary with General Goods and Promotional Items | Explains that goods imported under general merchandise names may still be subject to confirmation if used for food contact purposes. | The relationship with other import-related laws, labeling regulations, product safety, and household goods quality labeling is handled in separate articles. |
| Practical Handling by Freight Forwarders and Customs Brokers | Summarizes to what extent purpose, material, food contact surfaces, and necessary documents should be checked and communicated. | Final legal compliance judgments, test requirements, and sales acceptance decisions are the responsibility of importers, quarantine offices, and specialized institutions. |
Purpose and Background of the System
The food contact materials and packaging regulatory system is based on the idea that not only food itself but also utensils and packaging materials that touch food can pose food safety risks. Harmful substances may leach from parts that directly contact food, or materials unsuitable for use temperature or food type may be used, potentially affecting food safety.
For example, the glaze on ceramics, surfaces of glass or enamelware, metal plating or coatings, raw materials and additives in plastics, and inner coatings of paper containers cannot have safety judged by appearance alone. Therefore, it is necessary to confirm the materials of food contact parts, usage conditions, test reports, and compliance documentation.
In particular, synthetic resins used in food contact utensils and packaging are subject to a positive list system, which emphasizes using substances with confirmed safety under certain conditions. In import practice, simply knowing that an item is "plastic" is insufficient; it may be necessary to verify the resin used on the food contact surface, additives, coatings, usage temperature, and the type of food involved.
Situations Where the System Applies
Confirmation of food contact materials and packaging is not limited to cases importing food itself. Items imported for sale or business use that contact food—such as general goods, store fixtures, gifts, promotional items, or parts of food manufacturing machinery—may also be subject to these requirements.
| Scenario | Typical Cargo | Starting Point for Verification | Notes |
|---|---|---|---|
| Tableware and cooking utensils for retail sale | Plates, cups, pots, frying pans, knives, cutting boards | Material of parts that directly touch food | Even if the sales name is miscellaneous goods, if intended for food contact use, it may need to be confirmed. |
| Products for food storage and transport | Lunch boxes, storage containers, tumblers, water bottles | Composition of resin, metal, rubber packing, coating | For products made of multiple materials, confirmation per food contact surface is necessary. |
| Import of food packaging materials | Food packaging films, bags, paper containers, trays, labeled packaging materials | Layer contacting food and location of printing/adhesives | Material confirmation can be complex for multilayer films and inner surface coated items. |
| Equipment for stores and restaurants | Café cups, takeout containers, kitchen utensils | Use in business operations | Even if for in-house use, if used in business operations, it may require confirmation. |
| Promotional items and novelties | Logo mugs, tumblers, food storage bags | Intended use after distribution | Even if distributed free of charge, if intended for food-contact use, confirmation may be necessary. |
| Food manufacturing machinery and parts | Hoppers, piping, tanks, nozzles, blades, belts, filling parts | Parts directly contacting food | Material confirmation focuses on food-contact parts, not the entire machine. |
Application Requirements and Items Likely to be Excluded
Whether an item qualifies as utensils, containers, or packaging cannot be judged by product name alone. It is necessary to confirm in combination the import purpose, sales purpose, business use status, food contact use, material, and usage conditions.
| Category | Common Inclusion Criteria | Criteria Commonly Leading to Exclusion | Practical Verification Documents |
|---|---|---|---|
| Usage | Items that directly or indirectly contact food | Decorations, storage items, general miscellaneous goods that do not contact food | Catalogs, sales pages, user manuals, product photos |
| Import Purpose | Import for sale or business use | Personal use with no plan for sale or business use | Importer’s use explanation, sales plan, transaction contracts |
| Food Contact Surface | Food contact surfaces, inner surfaces, packing, coating, inner packaging layers | Outer packaging, boxes, transportation packing materials that do not contact food | Structure diagrams, material specifications, cross-section drawings, parts lists |
| Material | Synthetic resin, metal, glass, ceramics, paper, rubber, silicone, etc. | Outer materials without food-contact use or mere transport protection materials | Material certificates, test reports, manufacturer documentation |
| Usage Conditions | Items used with boiling water, microwave, oven, freezing, oily foods, acidic foods | Items not contacting food and unaffected by temperature or food condition | Heat resistance temperature, food type, and usage instructions |
| Machine Parts | Parts directly contacting food in food manufacturing processes | Frames, exteriors, control panels, and transport exteriors not contacting food | Food-contact parts lists, drawings, material specification tables by component |
Comparison with Other Systems
Utensils, containers, and packaging are not solely governed by the Food Sanitation Act. Notifications at import, material standards, sales labeling, product safety, and advertising claims are checked under separate systems. Clearing customs does not mean that sales labeling or advertising complies with all laws.
| System / Verification Area | Main Purpose | Relation to Utensils, Containers, and Packaging | Practical Notes |
|---|---|---|---|
| Food Sanitation Act | Ensuring safety of food and related products | Standards for utensils, containers, and packaging contacting food, import notification, inspection requirements are key issues. | If intended for sale or business use, even non-food items could be subject to notification. |
| Positive List System | Safety management of synthetic resins etc. used in food utensils and packaging | Important to verify raw materials, additives, and usage conditions when synthetic resin is used on food contact surfaces. | "Plastic-made" info alone is insufficient; resin type and additives must be checked. |
| Food Import Notification | Quarantine station procedure to confirm compliance with Food Sanitation Act at import | Utensils, packaging, and infant toys may also be subject to notification. | Before quarantine review, prepare usage info, materials, manufacturer data, and test reports. |
| Household Goods Quality Labeling Act | Quality labeling for consumer products | Material, handling, heat resistance labeling may become issues. | Separate verification of sales labeling is necessary beyond Food Sanitation Act confirmation at import. |
| Act against Unfair Labeling and Advertising | Prevention of misleading or exaggerated advertising | Claims regarding antibacterial properties, safety, harmlessness, environmental friendliness, heat resistance need a basis. | Even with test reports, avoid advertising claims that exceed the supported scope. |
| Product Safety Related Laws | Prevention of product accidents and consumer harm | Separate systems may apply for heating appliances, electrical cooking devices, infant products, etc. | Do not judge sales permissibility by Food Sanitation Act alone. |
Main Verification Points by Material
In utensils, containers, and packaging, the verification points vary depending on material. Especially when the material of the food contact surface cannot be identified, it is impossible to determine which standards or test reports need to be checked.
| Material | Representative Cargo | Items to Confirm | Common Issues |
|---|---|---|---|
| Synthetic Resin | Storage containers, packaging films, resin cooking utensils, resin-coated products | Type of resin, additives, food contact surface, usage temperature, compliance with positive list | Import arrangements may proceed without clear information on resin type or additives. |
| Ceramics, Glass, Enamel | Plates, cups, storage containers, decorative tableware | Leaching of lead, cadmium, etc., glaze, colored areas, food contact surface | For highly decorative products, it may be unclear whether the intended use is food contact or decoration. |
| Metal | Pots, frying pans, knives, cans, metal containers, machine contact parts | Type of metal, plating, surface treatment, coating, suitability for acidic foods or high temperature use | Verification items vary depending on stainless steel, aluminum, iron, copper, plating, etc. |
| Paper | Paper cups, paper plates, food packaging paper, paper containers | Inner coating, oil resistance processing, waterproofing, printing inks, adhesives | Though it looks like paper, the food contact surface may be a synthetic resin layer. |
| Rubber, Silicone | Gaskets, confectionery molds, cooking utensils, sealing parts of storage containers | Food contact use, heat resistance, leaching tests, food types used with, usage temperature | Heat resistance does not necessarily equate to suitability for food contact use. |
| Composite / Multilayer Materials | Multilayer films, laminated bags, coated containers | Food contact layer, intermediate layers, adhesives, outer layer printing, constituent materials | Confirmation may be required not only of the food contact layer but also the entire structure. |
Relation to the Positive List System
For food utensils and container packaging, the positive list system under the Food Sanitation Act is critical. Especially for synthetic resins that come into contact with food, it is generally required to use substances with confirmed safety.
In import practice, when synthetic resin is used on food contact surfaces, it is necessary to check material information, resin type, additives, compliance certificates, test reports, and manufacturer information. Simply labeling items as “plastic containers” or “food-use film” may be insufficient for compliance with the system.
Also, the positive list system does not uniformly regulate all materials used for utensils and container packaging in the same way. Metals, glass, ceramics, paper, etc., require verification of their respective standards and leaching criteria.
System Application Flow
When deciding on the import of utensils and container packaging, checking the product name alone is insufficient. It is important to verify actual use, sales purpose, food contact surfaces, materials, and required documentation in this order, leading to notification or inspection requirements.
| Step | Items to Confirm | Decision Approach | Next Actions |
|---|---|---|---|
| 1. Confirm Intended Use | Is there a food contact purpose? | Confirm actual use and sales explanations, not just product name. | Obtain catalogs, photos, sales pages, and instruction manuals. |
| 2. Confirm Import Purpose | Is the purpose for sales or business use? | Imports for sale, store use, business use, or promotion may require notification. | Check usage explanations with the importer. |
| 3. Identify Food Contact Surfaces | Which parts contact food? | Differentiation among main body, inner surface, gaskets, coatings, inner packaging layers. | Obtain structure diagrams, parts lists, and material sheets. |
| 4. Confirm Material | What materials are used on food contact surfaces? | Specify synthetic resin, metal, glass, ceramics, paper, rubber, silicone, etc. | Check material certificates and manufacturer documents. |
| 5. Confirm Standards and Test Documents | Are there standards or test reports? | Required tests and compliance documents vary by material. | Review test reports, compliance certificates, and positive list documents. |
| 6. Confirm with Quarantine Office | Are there unclear points about notification contents or inspection requirements? | If any uncertainties exist, it is safer to consult before import or customs clearance. | Consider prior consultation through importer or customs broker. |
Common Misunderstandings
For utensils and container packaging, shippers often assume "It doesn’t apply since it’s not food." However, under the Food Sanitation Act, not only food itself but also utensils and container packaging that contact food may be subject to checks.
| Common Misconception | Actual Concept | Practical Points to Note |
|---|---|---|
| Since it's not food, the Food Sanitation Act does not apply | Utensils and packaging that come into contact with food can also fall under the Food Sanitation Act’s confirmation requirements. | Confirm the intended use of tableware, cooking utensils, food packaging materials, and storage containers early. |
| No notification is needed if imported as miscellaneous goods | Even if classified as miscellaneous goods, if sold or used for food contact, confirmation is necessary. | Check product pages and catalog usage instructions. |
| It’s enough to know it’s made of plastic | With synthetic resins, factors like resin type, additives, usage conditions, and compliance with the positive list are key issues. | Obtain material certificates and compliance data from exporters or manufacturers. |
| Outer boxes that do not directly touch food are treated the same | Whether there is food contact is the important criterion; this differs from checking transport packaging or outer boxes. | Clearly separate layers, interiors, and components that contact food. |
| Since it is sold overseas as food-use, it is fine in Japan too | Japanese Food Sanitation Act standards and notification requirements must also be met separately. | Verify with quarantine offices or specialist bodies whether overseas standards alone are sufficient. |
| If it clears customs, labeling is not an issue either | Food Sanitation Act confirmation at import and labeling/advertising regulations at sale are separate practical matters. | Confirm heat resistance, microwave safety, antibacterial properties, and safety labels separately before sale. |
Cases That Often Cause Practical Issues
Utensils and packaging can cause customs clearance delays if Food Sanitation Act confirmation is only realized after shipment or right before customs clearance due to lack of documentation. Special attention is needed especially for first-time imports, items from new suppliers, composite materials, and promotional items.
| Case | Common Issues | Documents to Check | Practical Points to Note |
|---|---|---|---|
| Novelty Mugs | The shipper may not recognize the item as subject to the Food Sanitation Act because it is a free giveaway | Product photos, usage description, material certificates, test reports | Even free giveaways require confirmation if they contact food. |
| Plastic Storage Containers | Unclear resin type, additives, usage temperature, or type of food contact | Material list, positive list compliance documents, test reports | If labeled for microwave or freezer use, usage conditions must also be checked. |
| Paper Cups / Containers | Described as paper but internal resin coating exists | Cross-section structure, internal material, coating details | The layer contacting food must be identified for proper assessment. |
| Food Packaging Films | Multilayer structures, adhesives, printed surfaces, and food contact layers are unclear | Layer configuration charts, material data of food contact layers, test reports | Packaging materials cannot be judged by appearance alone, so manufacturer documentation is vital. |
| Parts of Food Processing Machines | Imported as machine parts, confirmation of food contact parts may be omitted | Parts lists, food contact parts lists, material certificates, drawings | Identify parts such as hoppers, pipes, belts, nozzles that contact food. |
| Ceramics and Decorative Tableware | Unclear if for decoration or food use, problems may arise with lead or cadmium leaching tests | Usage descriptions, food contact surfaces, glaze information, test reports | Even if imported as “decorative items,” sales descriptions suggesting tableware use require caution. |
Four-Column Judgment Checklist
Before import, roles and responsibilities of shippers, exporters, manufacturers, customs brokers, and quarantine offices should be separated and verified. Freight forwarders should not make all judgments but clarify who should confirm what.
| Point of Confirmation | Party to Confirm With | Items to Confirm | Actions if Issues Are Found |
|---|---|---|---|
| Before Booking | Shipper / Importer | Whether it is intended for food contact use, whether it will be sold or used for business | If for food contact, check early whether notification is required and what documents are needed. |
| Before Preparing Shipping Documents | Exporter / Manufacturer | Product name, materials, food contact surfaces, manufacturer information | If invoice product names are insufficient, obtain catalogs and material sheets additionally. |
| Before Customs Clearance Arrangement | Customs Broker | Need for Food Import Notification, required attachments, need for quarantine consultation | If decision is difficult, consider pre-consulting the quarantine office. |
| When Confirming Materials | Manufacturer / Supplier | Material of food contact surfaces, resin, additives, coatings, gasket materials | If materials are unclear, it may be necessary to revise the import schedule. |
| At Inspection or Review | Quarantine Office / Specialist Bodies | Test reports, compliance with standards, need for inspections | If additional documentation or testing is needed, share with stakeholders assuming clearance delays. |
| At Sale Preparation | Importer / Sales Personnel | Evidence for heat resistance, microwave safety, dishwasher safety, antibacterial and safety labeling | Confirm labeling and advertising expressions separately from import confirmation. |
Comparison Table of Forwarder Involvement Scope
Forwarders and customs brokers play a role in early detection of potential Food Sanitation Act issues during logistics arrangement and customs processes. However, they should not make final legal compliance judgments nor decide on testing or sales approval.
| Category | What can be easily supported | What should not be concluded definitively | Practical handling |
|---|---|---|---|
| Purpose confirmation | Confirm with the shipper whether the product is for food contact use | Definitively state that it is outside the scope of the Food Sanitation Act | If the use is unclear, request submission of sales pages or catalogs. |
| Document guidance | Inform that material certificates, test reports, and manufacturer information may be required | Guarantee that import is always possible based on submitted documents alone | Connect to customs brokers or quarantine authorities for confirmation. |
| Schedule management | Share the risk of customs clearance delays due to lack of documents in advance | Promise that processing can always be done on the usual customs clearance schedule | Suggest shipping and delivery schedules with sufficient margin for first-time imports. |
| Positive list | Inform that compliance documents may be an issue for synthetic resin products | Conclude the compliance of individual substances without expert confirmation | Guide toward manufacturer documents, specialized agencies, and quarantine office confirmation. |
| Sales labeling | Advise that import confirmation and sales label verification are separate matters | Definitively conclude the legality of microwave-safe, antibacterial, safety labels, etc. | Advise importers to check sales labeling and advertising regulations. |
| Machine parts | Confirm whether there are food contact parts | Make a blanket judgment that the entire machine is either out of scope or within scope | Separate parts that touch food using drawings and parts lists. |
Typical Situations Where the System Becomes an Issue
In the case of utensils, containers, and packaging, the later the importer realizes that the cargo is subject to regulations, the more likely customs clearance delays and changes to sales plans will occur. It is especially important to note that products that are not food themselves are more prone to confirmation oversights.
| Typical Situation | Common Issues | Party / Documents to Confirm | Practical handling |
|---|---|---|---|
| First-time import of kitchenware | Shipment without awareness that it is subject to the Food Sanitation Act notification | Importer, customs broker, product catalog, material certificates | Confirm purpose and materials before the first import, and prepare required documents before shipment. |
| Samples for exhibitions | Unclear whether it will be sold or distributed after the exhibition | Exhibition plan, distribution plan, import purpose explanation | Clarify whether it is for exhibition only or intended for sales and promotional use. |
| Overseas miscellaneous goods for e-commerce sales | Sales page shows “for food use,” but import documents list as miscellaneous goods | Sales page, product description, invoice, material documents | Align product names on documents with actual sales usage. |
| Multi-layer food packaging films | Insufficient information on food contact layers, adhesives, and printed surfaces | Layer composition sheet, manufacturer documents, test reports | Check not only the food contact layers but also all constituent materials. |
| Parts for food production lines | Treated as machine parts with overlooked confirmation of food contact materials | Drawings, parts list, list of food contact parts, material certificates | Separate parts that contact food and confirm their materials. |
| Usage change after sales | Products originally imported as decorations are sold as food-use items | Sales labeling, product description, background of usage change | If the intended use changes between import and sales, reconfirmation is necessary. |
System Application Scenario 1: Importing Logo-Branded Tumblers as Novelties
When importing tumblers with corporate logos as promotional items, it is not necessarily true that Food Sanitation Act confirmation is unnecessary just because they will be distributed for free. If it is expected that the tumblers will be used to hold beverages after distribution, they may be subject to food contact utensil regulations.
In this case, the points to be confirmed include the material of the main body, inner surface coating, drinking edge, gasket, heat resistance, and types of permissible beverages. Even if made of stainless steel, if there is interior treatment or resin parts used, material confirmation for each food contact surface may be required.
Freight forwarders should not treat them as ordinary miscellaneous goods based solely on their novelty item status but should confirm with the shipper whether they will be used as drink containers and, if necessary, refer the matter to customs brokers or quarantine offices for confirmation. This approach is safer.
System Application Scenario 2: Importing Multi-layer Food Packaging Films
Food packaging films may appear as a single film on the surface but consist of multiple layers, adhesives, printed surfaces, and coatings. Without confirming which materials touch food directly, it is impossible to determine which regulatory standards or positive list compliance documents need to be checked.
Especially for packaging used with fatty foods, frozen foods, microwave-heated foods, and hot-filled foods, tests and required documentation may differ based on usage conditions. Food packaging materials may require explanations of not only the food contact layers but also the full composition of materials.
Before import, it is important to check the layer composition sheet, materials of food contact layers, usage temperature, food types, test reports, and manufacturer information. Shipping without complete documents may cause delays during quarantine confirmation or customs screening.
System Application Scenario 3: Importing Parts for Food Manufacturing Machinery
When importing food manufacturing machinery, it is not the entire machine treated uniformly as utensils, containers, and packaging, but rather the parts that directly contact food that are relevant. Hoppers, piping, tanks, nozzles, blades, belts, filling components, molding sections, and so forth may require material confirmation as food contact parts.
On the other hand, control panels, outer frames, and covers that do not come into contact with food have different verification criteria than food contact materials. Therefore, it is necessary to distinguish parts that come into contact with food from those that do not by using parts lists and drawings.
In import operations, it is not possible to judge by machine name alone. It is necessary to obtain a list of food contact parts, material certificates, manufacturer documentation, and test reports if required from exporters and manufacturers. When importing food manufacturing machinery, it is important to consider customs clearance as machinery equipment separately from compliance with the Food Sanitation Act regarding food contact materials.
Commonly Needed Documentation
In imports of utensils, containers, and packaging, whether the importer can gather documentation early in the process is a critical factor to prevent customs clearance delays. Especially for initial imports, products from new manufacturers, composite material products, or those where food contact surfaces are unclear, it is essential to verify documents before shipment.
| Document | Details Confirmed | Source | Impact if Missing |
|---|---|---|---|
| Product Catalog or Sales Page | Usage, presence or absence of food contact, explanation at time of sale | Importer, Seller, Exporter | Initial judgment on whether subject to the Food Sanitation Act becomes difficult. |
| Product Photos or Structural Diagrams | Food contact surfaces, component parts, usage method | Exporter, Manufacturer | Unable to identify parts that contact food. |
| Material Certificate | Material of food contact surfaces, resin, metal, coating | Manufacturer, Supplier | Difficult to determine applicable standards and testing requirements by material. |
| Test Reports | Migration tests, material tests, standard compliance | Manufacturer, Testing Organization | Quarantine inspection and importer verification may be delayed. |
| Positive List Compliance Documents | Raw materials, additives, and usage conditions of synthetic resins | Manufacturer, Raw Material Producer | Confirming compliance of synthetic resin products becomes difficult. |
| Manufacturer Information | Factory location, manufacturing process, quality control information | Exporter, Manufacturer | Additional inquiries may occur during initial imports or quarantine inspections. |
Relationship with Sales Labels and Explanations
Even after completing import confirmation under the Food Sanitation Act, there is no automatic assurance that sales labels, usage instructions, or advertising expressions are compliant. At the sales stage, other laws such as the Household Goods Quality Labeling Act, the Act against Unjustifiable Premiums and Misleading Representations, and product safety-related regulations may apply.
Particularly, labels emphasizing microwave-safe, oven-safe, dishwasher-safe, heat resistance, freezer-safe, antibacterial, harmlessness, and safety require verification of supporting documents and display rules. Import confirmation under the Food Sanitation Act and verification of sales labeling and advertising are separate operational processes.
Importers should take care not to assume that clearance at customs automatically means sales labeling is lawful. Usage conditions stated on sales pages or product packaging need to be consistent with test reports and manufacturer documentation.
Summary
Utensils, containers, and packaging refer to tableware, cooking utensils, containers, and packaging materials that come into contact with food, and when imported for sale or business purposes, confirmation under the Food Sanitation Act may be required. Since these are not food products themselves, they tend to be overlooked, but if they are intended to contact food, import declarations, material verification, test reports, and positive list compliance documents may become issues.
The practical starting point is not the product name but whether it has a food-contact application, where the food contact surfaces are, and what materials they are made of. For synthetic resins, compliance with the positive list system is important. For ceramics, glass, metals, paper, rubber, silicone, etc., confirming applicable standards and migration limits specific to each material is an issue.
Importers, customs brokers, and freight forwarders should not judge based solely on generic product names, but rather verify catalogs, photos, usage explanations, material certificates, and test reports early. In utensils, containers, and packaging imports, confirming usage, materials, and food contact surfaces is central to preventing customs delays and post-import sales issues.
