Positive List System for Food Contact Materials and Packaging
Interlink編集部What is the Positive List System for Food Contact Utensils and Packaging Materials?
The positive list system for food contact utensils and packaging materials is a framework that lists substances whose safety has been confirmed for use in raw materials that come into contact with food. It permits the use of substances only within this list. This system ensures the safety of items that directly touch food, such as tableware, cooking utensils, food containers, and packaging materials.
In import operations, even cargo that is not food itself may require confirmation under this system if it is intended for use in contact with food. This confirmation is especially important for food contact utensils and packaging made of synthetic resins, commonly known as plastics.
An important point of this system is that it is not sufficient to confirm only whether “listed substances are used.” It is necessary to verify whether the actual usage conditions align with the system requirements, including the base material, additives, usage conditions, temperature of use, food contact surfaces, type of food, and contact duration.
Scope Covered in This Article
The positive list system for food contact utensils and packaging is related to multiple topics, including utensil and packaging materials, the Food Sanitation Act, import food notifications, material testing, manufacturer certification, and labeling. This article focuses on understanding the system and practical confirmation tasks required in import operations. Detailed guidance on creating individual notification documents and food labeling is covered in related articles.
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basic System | Explanation that this system regulates the use of substances confirmed to be safe in synthetic resins used in food contact utensils and packaging materials. | The overall structure of the Food Sanitation Act is explained in detail in the article “Food Sanitation Act”. |
| Relation to Utensils and Packaging Materials | Focus on cases where synthetic resin is used on food contact surfaces of tableware, cooking utensils, food containers, and packaging materials. | Basic determination of cargo classified as utensils or packaging is explained in detail in the article “Food Utensils, Containers and Packaging”. |
| Relation to Import Food Notification | Explanation about when food contact utensils and packaging imported for sale or business purposes may require food import notification. | Notification procedures, certificates of notification, and quarantine inspection are detailed in “Imported Food Notification” and “Food Import Notification Form”. |
| Target Materials | Clarification that synthetic resin is the main target of the system and the importance of confirming the material at the food contact surface. | Material-specific confirmation for metals, ceramics, glass, paper, rubber, silicone, etc., are addressed in their respective material-specific articles. |
| Confirmation Practices | Handling of how to check base materials, additives, usage conditions, manufacturer certifications, test reports, and information sharing. | Details of testing methods, migration tests, and standards are addressed in testing and inspection related articles. |
| Forwarder and Customs Broker Involvement | Practical guidance on early confirmation of food contact purpose, presence of food contact surfaces, use of synthetic resins, and necessary documents. | Final legal compliance judgments, substance-specific list confirmation, and consultation on new substances are tasks for importers, manufacturers, and expert agencies. |
Purpose and Background of the System
Food contact utensils and packaging materials come into direct or indirect contact with food, which means ingredients in the materials may migrate into the food. Even if the food itself is safe, the migration of harmful substances from containers, packaging materials, cooking utensils, or food processing equipment’s food contact parts can cause food safety problems.
The positive list system lists substances authorized for use in food contact utensils and packaging, permitting their use only when safety has been confirmed. Unlike a system that prohibits only individually problematic substances, this approach clearly defines the substances that can be used.
In import logistics practice, products labeled overseas as “food grade” or “safe for food contact” are not necessarily compliant with Japan’s positive list system. Importers need to confirm the materials of the food contact surfaces, the base materials and additives used, and the conditions of use, and prepare documentation that explains compliance with the Japanese system.
Implementation History and Transition Measures
The positive list system for food contact utensils and packaging materials was introduced through an amendment to the Food Sanitation Act and came into force on June 1, 2020. Upon introduction, transition measures were established to accommodate existing products in circulation and current raw materials.
These transition measures expired on May 31, 2025. From June 1, 2025, onward, compliance confirmation must be based directly on the current positive list, rather than transitional explanations.
In import practice, products that were previously allowed importation may not necessarily continue to be freely imported. For ongoing imports, specification changes, supplier changes, changes in packaging materials, or changes in the materials on food contact surfaces, reconfirmation in line with the post-transition operational framework of the system is necessary.
Situations Where the System Applies
The positive list system is particularly important for cases where synthetic resins are used on food contact surfaces of food contact utensils and packaging materials. Even if the product name indicates sundries, kitchenware, containers, packaging materials, or machinery parts, if the item is intended for food contact use, confirmation under the system may be required.
| Scenario | Common Relevant Cargo | Main Points for Confirmation | Practical Logistics Notes |
|---|---|---|---|
| When importing food storage containers | Plastic containers, lunch boxes, storage cases, airtight containers | Resin of food contact surfaces, additives, packing materials, usage temperature | Check conditions for use with freezing, microwave, boiling water, and oily foods. |
| When importing food packaging materials | Food packaging films, food bags, laminated packaging materials, multilayer films | Food contact layer, base material, additives, adhesives, position relative to printed surface | For multilayer structures, explanations may be required not only for the food-contacting layer but for the entire structure. |
| When importing paper containers | Paper cups, paper plates, paper containers, takeout containers | Inner synthetic resin coating, laminate material, waterproof and oil-resistant processing | Even if the appearance is paper, if the food-contacting surface has a synthetic resin layer, it may need to be checked. |
| When importing parts of food manufacturing machinery | Hoppers, piping, belts, packing, nozzles, filling sections | Material and usage conditions of parts in direct contact with food | Focus on the food-contact parts, not the entire machine, for confirmation. |
| When importing novelty containers | Tumblers, bottles, mugs, lunch boxes, storage containers | Food contact purpose, food contact surfaces, resin parts, manufacturer certification | Even for free distribution, if intended for food contact use, confirmation may be required. |
| When there are specification or supplier changes | Continually imported containers, packaging materials, packing, films | Material changes, additive changes, manufacturer changes, grade changes | Confirm whether past test reports or certificates are applicable to the new specifications. |
Applicable Conditions and Common Exclusions
For the positive list system checks, it is important to verify the material of the parts that contact food, rather than the entire product's material. The outer packaging or transport packaging that does not contact food should be considered separately from the synthetic resin used on food contact surfaces.
| Category | Concepts More Likely To Require Confirmation | Concepts More Likely To Be Excluded or Need Separate Confirmation | Documents / Information to Check |
|---|---|---|---|
| Food contact usage | Items that directly or indirectly come into contact with food | Decorative items not touching food, external transport packaging, general storage products | Catalogs, sales pages, usage instructions, purpose explanations |
| Food contact surface | Inner surfaces, packing, coating, inner layer of packaging, presence of synthetic resin in food-contact components | Outer surfaces not touching food, outer boxes, transport protective materials | Structural diagrams, cross-section diagrams, parts lists, descriptions of food contact surfaces |
| Target material | Synthetic resin used on food-contact surfaces | Metals, glass, ceramics, paper, wood without synthetic resin layers | Material certificates, base material information, additive details |
| Composite materials | Paper, metal, fabric with synthetic resin laminates or coatings | Structures where the synthetic resin layer does not contact food | Layer composition tables, laminate structure, material of food-contact layer |
| Usage conditions | Expected use with high temperature, oily foods, acidic foods, long-term storage, microwave usage | Non-food contact or limited use cases potentially excluded under the Food Sanitation Act | Usage temperature, contact time, type of food, usage methods |
| Import purpose | Imported for resale or business use | For personal use, not for resale or business use | Import purpose, sales plans, distribution plans, presence of business use |
Comparison With Other Systems
The positive list system is part of the safety confirmation of food utensils, containers, and packaging. It differs in purpose and points of confirmation from food import notification, material-specific standards, elution tests, manufacturing management, food labeling, and product safety. Passing customs clearance does not guarantee compliance with sales labeling or product safety.
| System / Area of Verification | Main Purpose | Relation to Positive List System | Practical Points of Caution |
|---|---|---|---|
| Positive List System | Safety management of raw materials for synthetic resins used in food contact applications | Check if base materials, additives, and usage conditions comply with the list. | Simply being labeled as "for food use" is not sufficient. |
| Food and Related Imports Notification | Procedure to notify Quarantine Station of food contents upon import | Relevant if importing utensils, containers, or packaging for sale or business purposes. | Material certificates or test reports may be requested during notification review. |
| Material-Specific Standards & Elution Criteria | Check safety and elution risk according to material type | Material-specific standard checks may be required separately from Positive List compliance. | Confirm that items covered by test reports, conditions, and model numbers match the imported cargo. |
| Manufacturing Control & Information Transmission | Convey raw material usage and compliance info from the manufacturer | Essential for importers to grasp compliance status. | If overseas manufacturers do not understand the Japanese system, document acquisition may take time. |
| Food Labeling and Sales Marking | Ensure proper labeling and handling instructions at the point of sale | Separate from import confirmation under the Food Sanitation Act; heat resistance, microwave-ability, and dishwasher compatibility can be issues. | It is important not to confuse import confirmation with sales labeling verification. |
| Product Safety Related Laws | Prevent product accidents and consumer harm | Other systems may overlap for heating appliances, electrical products, infant goods, etc. | Be cautious not to make sales eligibility decisions based solely on Positive List compliance. |
Three-Layer Structure of the Positive List
In the Positive List System, it is necessary to verify not only whether the substance name is listed but also the relationship between the base material, additives, and usage conditions. Even if the base material complies, if the additives or usage conditions do not align, the product may still pose problems in practice.
| Verification Layer | Meaning | Documents to Check | Practical Points of Caution |
|---|---|---|---|
| Base Material | The polymer or substances constituting the backbone of the synthetic resin. | Base material name, resin name, grade, constituent monomers, material certificate | General names like polyethylene or polypropylene alone may be insufficient. |
| Additives | Substances used to impart functionality to synthetic resin. | Additive lists, formulation info, specifications, manufacturer certificates | Includes stabilizers, antioxidants, lubricants, colorants, etc. |
| Usage Conditions | Conditions such as type of food, usage temperature, contact time, amount used, and intended purpose. | Usage instructions, specifications, sales pages, test conditions, compliance certificates | Verification criteria differ between ambient dry foods and high-temperature or oily foods. |
| Food Contact Surface | The actual surfaces or parts that come into contact with food. | Structural diagrams, cross-sectional views, parts lists, explanatory documents about food contact surfaces | Identify specific layers or parts touching food, not the whole product. |
| Product Specifications | The actual part number, lot, specifications, and manufacturer of the imported product. | Part number, specifications, manufacturer info, lot info, test reports | Confirm that past certificates do not pertain to different specifications or part numbers. |
| Information Transmission | Mechanism for manufacturers to convey compliance information to importers and sellers. | Compliance certificates, declarations, supplier explanations, transaction documents | Check early whether overseas manufacturers can prepare materials suitable for the Japanese system. |
Practical Methods for Confirming Compliance
When confirming Positive List compliance, review the Positive List published by the Consumer Affairs Agency, related notices, and Q&A, etc. However, if importers or freight forwarders only look at the list, they cannot judge without knowing what substances are actually used in the product.
In practice, obtain from the manufacturer material information, base material info, additive info, the structure of food contact surfaces, usage conditions, and compliance certificates, and organize them so they can be explained against the Japanese system. If necessary, check test reports and results of material or elution tests from third-party testing organizations.
The important point is that simply labeling as "for food use," "food grade," or "BPA free" may not be sufficient for confirming compliance with Japan's Positive List system. Materials that can explain the base material, additives, usage conditions, and food contact surface according to Japan’s system are required.
Application Flow of the System
For Positive List system verification, it is practical to start not from the product name but from food contact usage, food contact surfaces, presence of synthetic resin, base materials/additives, usage conditions, and then certification documents, in that order.
| Step | What to Confirm | How to Decide | Next Action |
|---|---|---|---|
| 1. Confirm Food Contact Usage | Is it used in direct or indirect contact with food? | Judgment is based on actual usage and sales descriptions, not just product name. | Check catalogs, photos, sales pages, and usage instructions. |
| 2. Identify Food Contact Surface | Which surface, layer, or component touches the food? | Distinguish inner surfaces, coatings, gaskets, inner packaging layers, etc. | Obtain structural diagrams, cross-sections, and component lists. |
| 3. Confirm Presence of Synthetic Resin | Is synthetic resin used on the food contact surface? | Even if the item is paper or metal, it may be subject to confirmation if it has a resin coating on the inner surface. | Review material certificates and layer composition charts. |
| 4. Confirm Base Material and Additives | Can you identify the base material, additives, grade, and standards? | Information enabling comparison with the positive list is required beyond generic names. | Obtain manufacturer's certificates, specification sheets, and declarations of conformity. |
| 5. Confirm Usage Conditions | Usage temperature, food type, contact duration, suitability for microwave, boiling water, oily foods | Even substances listed may cause issues depending on usage conditions. | Verify that usage and test conditions align. |
| 6. Reflect in Declarations and Customs | Can it be reflected in import notifications for food, quarantine inquiries, and customs declarations? | Lack of documentation may delay notification examination and customs clearance. | Share confirmation points with importer, customs broker, and quarantine office. |
Common Misunderstandings
The positive list system often leads to misunderstanding such as "It's okay because it says ‘food use’," "It's fine if BPA free," or "If it's not plastic, it's irrelevant." Official confirmation under the system should be based on the material of the food contact surface and the conditions of use, not on labeling statements.
| Common Misunderstanding | Actual Understanding | Practical Notes |
|---|---|---|
| If it says "food grade" it is acceptable in Japan | Overseas food contact usage labels do not necessarily mean compliance with Japan's positive list. | Check documentation of base materials, additives, and usage conditions according to Japanese regulations. |
| If it is BPA free, it complies with the positive list | BPA non-use is a declaration concerning limited substances and does not prove full compliance with regulations. | Comprehensive confirmation of base materials, additives, and the entire food contact surface is necessary. |
| Only plastic products need checking | Paper containers, metal containers, and composites with synthetic resin layers on food contact surfaces may also require confirmation. | Focus on the layers or components touching food, not just exterior appearance. |
| If the product was imported before without issue, it will be fine going forward | After grace periods expire, confirmation based on current regulatory practices is essential. | Even for continuing imports, check certificates, specifications, and any supplier changes. |
| If a test report exists, the product definitely complies | Test reports are important but must match the specific product, part number, material, and test conditions. | Confirm identity between the imported cargo and tested sample. |
| The freight forwarder will decide compliance | Freight forwarders can assist with confirmation but do not make final decisions on substance compliance. | Coordinate with importer, manufacturer, specialized institutions, and quarantine authorities. |
Cases Commonly Problematic in Practice
In the positive list system, issues often arise with cargo that is not food itself and where the shipper does not recognize it as subject to food sanitation laws. Confirmations tend to be delayed especially for miscellaneous goods, packaging materials, novelties, machine parts, and composite materials regarding food contact surfaces.
| Case | Common Issues | Documents to Confirm | Practical Notes |
|---|---|---|---|
| Plastic Storage Containers | Details of base materials and additives are unclear, making positive list verification difficult | Material certificates, base material info, additives info, manufacturer’s certificates | Descriptions such as “made of plastic” alone are insufficient. |
| Paper Cups and Paper Containers | Stated as paper but inner surface may have synthetic resin coating | Layer configuration charts, inner surface material, coating material info | Clarify whether the food contact surface is paper or a resin layer. |
| Multi-layer Film and Laminated Packaging | Unclear relationship between food contact layer, adhesives, intermediate layers, and printing surface | Cross-section configurations, layer composition, food contact layer materials, test reports | Packaging materials cannot be judged by appearance alone. |
| Novelty Tumblers | Handled as promotional items, and food contact use confirmation is overlooked | Product photos, usage instructions, material certificates, food contact surface info | Confirmation is necessary when used as beverage containers, even if distributed for free. |
| Resin Parts of Food Manufacturing Machines | Imported as machine parts and food contact parts are overlooked | Parts lists, drawings, food contact parts lists, material certificates | Separate food contact parts from the entire machine. |
| Products Where Overseas Manufacturers Do Not Disclose Formulation Info | Details on base materials and additives cannot be confirmed citing confidentiality | Manufacturer certificates, declarations of conformity, quarantine submission documents, explanations of non-disclosure scope | Shipping with incomplete documents may cause delays in notification review and customs clearance. |
4-Column Decision Checklist
With the Positive List System, information tends to be scattered among importers, exporters, manufacturers, customs brokers, and freight forwarders. Especially regarding the materials of food contact surfaces and usage conditions, importers alone often cannot grasp the full picture, making it important to obtain documentation from manufacturers.
| Verification Stage | Counterparty to Check | Items to Confirm | Actions if Issues Arise |
|---|---|---|---|
| Inquiry / Quotation | Shipper / Importer | Whether for food contact use, and whether for sales or commercial use | If for food contact use, provide early guidance on notification requirements and necessary documents. |
| Before Shipment | Exporter / Manufacturer | Food contact surfaces, use of synthetic resin, substrate and additive information | If documentation is insufficient, consider shipment delay or prior consultation. |
| Document Review | Manufacturer / Supplier | Manufacturer’s certification, conformity declaration, test report, applicable product numbers | Confirm that the imported cargo matches the certificates and test targets. |
| Notification Preparation | Customs Broker / Quarantine Office | Whether food import notification is required, attached documents, possibility of additional inquiries | If judgment is difficult, connect to quarantine office consultation or expert confirmation. |
| Specification Changes | Importer / Manufacturer | Changes in material, additives, manufacturer, production site, grade, layer structure | Confirm if past documentation can be reused and re-obtain if necessary. |
| Sales Preparation | Importer / Sales Department | Usage temperature, microwave compatibility, dishwasher compatibility, heat resistance labeling, usage conditions | Separate from import confirmation, check consistency with sales labels and handling instructions. |
Comparison Table of Freight Forwarder Involvement Scope
Freight forwarders and customs brokers are not in a position to make the final decision on conformity with the Positive List System. However, their role in early detection of cargo for food contact use, urging necessary documentation acquisition, and sharing risks of customs clearance delays is important.
| Category | Assistance Likely | Should Not Decide | Practical Response |
|---|---|---|---|
| Confirmation of Cargo Subject | Check with shipper whether cargo is for food contact use | Unilaterally conclude the cargo is outside Food Sanitation Act scope | If use is unclear, request catalogs or sales pages for submission. |
| Material Confirmation | Prompt confirmation whether synthetic resin is used on food contact surfaces | Decide conformity with Positive List solely based on material name | Guide to obtain material certification, substrate info, and additive info. |
| Document Guidance | Inform that manufacturer certification, conformity declarations, and test reports may be required | Guarantee import is always possible if documents are available | Explain documents are prerequisites for examination but separate from conformity judgment. |
| Schedule Management | Share risk of notification examination/customs clearance delays due to document insufficiency | Promise customs clearance on the usual schedule as general cargo | Set a schedule with buffer time for first imports or products from new suppliers. |
| Response to Quarantine Office Inquiries | Communicate requests for additional documents to the importer | On own judgment, confirm inclusion in listings or usage condition conformity per substance | Connect importer, manufacturer, experts, or quarantine office as needed. |
| Sales Label Precaution | Inform that import confirmation and sales label confirmation are separate | Decide legality of microwave use, heat resistance, or safety labeling | Encourage importers to check labeling, advertising, and product safety themselves. |
Typical Situations Where the System Causes Problems
A typical problematic situation with the Positive List System is when logistics arrangements progress on the assumption the cargo is non-food, but food contact use is later found. Starting to gather material certification and conformity proof after cargo arrival tends to affect quarantine office examination, customs clearance, and delivery schedules.
| Typical Scenario | Common Issues | Parties / Documents to Check | Practical Actions |
|---|---|---|---|
| Kitchenware imported as miscellaneous goods | The shipper is unaware the items are for food contact use | Importer, sales page, product catalog, instructions for use | First, verify whether the items are intended to touch food. |
| Packaging materials imported as general plastic products | Material data is not prepared despite the items being food packaging materials | Manufacturer, material certificates, layer structure charts, compliance certificates | Verify the food contact layer and usage conditions before shipment. |
| Supplier change for continuously imported goods | Previous certificates cannot be used for new manufacturers or specifications | Old and new specifications, manufacturer info, material info, test reports | Reconfirm even for continuous products if there are any changes. |
| Only test reports submitted | Unable to confirm identity between tested items and imported goods | Item numbers, lot numbers, specifications, test conditions, target materials | Confirm correspondence between certificates, test reports, and imported cargo. |
| Overseas manufacturer does not understand the Japanese system | Only "food grade" certificates are submitted without Japan-specific compliance documents | Manufacturer certificates, conformity declarations, base materials, additives info | Specify the confirmation items required under the Japanese system. |
| Imported as parts of food manufacturing machines | Handling as machine parts leads to omission of food contact material checks | Parts lists, drawings, food contact parts lists, material certificates | Separate and verify only the parts that come into contact with food. |
Scenario for System Application 1: Paper Containers with Resin Coating on the Inside
Paper cups and paper containers may be misunderstood as unrelated to the Positive List system because they visually appear to be paper products. However, when a synthetic resin coating or laminate layer is applied on the inside for waterproofing or oil resistance, the food contact surface must be verified as the resin layer rather than paper in some cases.
In such cases, importers should check not only the paper type but also the material of the food contact inner layer, coating material, usage temperature, applicable foods, and test reports. When hot beverages, oily foods, or microwave heating are involved, consistency between usage conditions and test conditions also becomes a concern.
Freight forwarders and customs brokers should confirm with the shipper whether a synthetic resin layer exists on the food contact surface, even if the invoice description is "paper cup" or "paper container". If sold for food use, it is important to start preparing compliance documents and understand notification requirements early.
Scenario for System Application 2: Importing Novelty Tumblers
When importing corporate logo tumblers or bottles as novelties, it is not always the case that food sanitation law checks are unnecessary just because the items are distributed free of charge. If it is assumed that these will be used to hold beverages after distribution, they may be subject to verification as food contact utensils.
Tumblers may have multiple food contact parts such as the inner body, drinking spout, lid, packing, straw, or coating. Even if the item appears stainless steel or glass, if synthetic resin is used in lids or packing, compliance with the Positive List for those parts becomes an issue.
In practice, the entire product is not judged as one unit; the material and usage conditions of each food contact part are verified. It is necessary to check which parts the manufacturer certificates and test reports cover and confirm that the import item codes correspond to those on the certificates.
Scenario for System Application 3: Importing Resin Belts for Food Manufacturing Machines
When importing resin belts, packing, nozzles, hoses, etc., as parts of food manufacturing machines, it is necessary to verify not only customs clearance as machine parts but also food contact materials. If the parts come into direct contact with food, they may need to be confirmed as food utensils and container packaging.
Documents to be checked include parts lists, drawings, food contact parts lists, material certificates, manufacturer certificates, and usage conditions. It is necessary to distinguish between frames or outer parts that do not touch food and belts or packing that do and verify accordingly.
Freight forwarders and customs brokers should confirm whether items labeled as "machine parts" are used in food production lines and if they contact food. If food contact parts are involved, it is important to inform the shipper that document checks may take longer than for regular machine parts.
Manufacturer Certificates and Test Reports
The Positive List system relies heavily on information from manufacturers. If importers cannot grasp the material and compliance status of products, quarantine inspections and explanations to sales destinations become difficult.
Manufacturer certificates should ideally confirm the materials, base materials, additives, applicable standards, and usage conditions of food contact surfaces. However, since manufacturers may treat formulation data as confidential, it is necessary to negotiate in advance how much information can be disclosed.
Test reports document results of material testing, migration testing, etc. However, having test reports does not automatically confirm Positive List compliance. It is essential to verify that the tested items, item numbers, specifications, materials, test conditions, food contact surfaces, and usage conditions match the actual imported cargo.
When Unlisted Substances Are Used
If raw materials of synthetic resins used in food contact surfaces are not listed in the Positive List, their use in food utensils and container packaging is generally not allowed. When there is a possibility that unlisted substances are used, importers must confirm material information with the manufacturer and clarify usage locations and food contact status.
In actual logistics practice, considerations include changes to alternative materials, limiting contact to non-food-contact surfaces, the presence or absence of barrier layers, and whether consultation on new substances is required. If the importer cannot explain compliance, additional documents may be requested by the quarantine office, or the review of the food import notification may not proceed.
As a result, delays in customs clearance, changes in sales plans, loading back, or disposal may occur. If there is a possibility of undeclared substances, it is important to check this before starting the transaction or before shipment, rather than after the cargo arrival.
The Importance of Information Communication
Under the Positive List System, it is crucial to properly communicate information related to raw materials used and compliance status among manufacturers, exporters, importers, sellers, and food business operators. If the importer cannot understand the product’s material or compliance status, they may not be able to respond to confirmations at the quarantine office or explain to the sales destination’s inquiries.
In particular, manufacturers may not understand Japan’s Positive List System regarding packaging materials, containers, packing materials, or parts of food manufacturing machines. General food contact certificates provided by overseas suppliers may not satisfy the confirmation items required under the Japanese system.
In practice, it may be insufficient to rely solely on catalog descriptions such as “for food use” or “safe for food contact.” It is important to confirm specific materials, food contact surfaces, usage conditions, and the basis for compliance from the manufacturer or exporter.
Summary
The Positive List System for utensils and containers/packaging for food requires the use of substances confirmed to be safe in synthetic resin utensils and containers that contact food. The system came into effect on June 1, 2020, with transitional measures ending on May 31, 2025.
Verification under the system requires more than simply checking if a substance is “on the list.” It is necessary to confirm whether the actual usage conditions—such as base material, additives, usage conditions, food contact surfaces, usage temperature, type of food, and contact time—are in accordance with the requirements.
Importers, customs brokers, and freight forwarders need to verify, before shipment, whether the product is for food contact use, the presence or absence of synthetic resin, materials of the food contact surface, manufacturer certifications, and test reports. Under the Positive List System, the communication of information and confirmation of the basis for compliance are key to preventing customs delays and post-import sales troubles.
