Positive List System for Food Contact Utensils, Containers and Packaging in Japan

Overview

The Positive List System for food contact utensils, containers and packaging in Japan is a regulatory system that controls the substances used in materials that come into contact with food.

Under this system, only substances whose safety has been evaluated and listed may, in principle, be used for covered materials. The system is especially important for synthetic resins used in food containers, packaging films, kitchenware, tableware and other food-contact products.

For overseas suppliers and origin-side forwarders, the important point is that a product may be subject to food sanitation controls even if it is not food itself. If the product is intended to contact food, Japanese food sanitation requirements may apply.

Purpose of the System

Food contact utensils, containers and packaging may transfer substances from their material into food. For this reason, Japan controls the materials and additives used in food-contact products to protect food safety and consumer health.

The positive list approach does not simply prohibit dangerous substances after a problem is found. Instead, it identifies substances that may be used, and permits use within the listed scope and applicable conditions.

Products Commonly Covered

The system may become relevant to products that are used in contact with food. Examples include:

• food storage containers;
• lunch boxes;
• food packaging films;
• food bags and pouches;
• plastic food containers;
• kitchen utensils;
• tableware;
• food-contact parts of food manufacturing machinery;
• caps, inner plugs, gaskets and seals for food containers;
• food packaging materials.

In practice, products described as “miscellaneous goods,” “kitchen goods,” “containers” or “packaging materials” may still require confirmation if they are intended to contact food.

Materials Covered by the Positive List

As of the post-transitional system effective from June 1, 2025, the main covered material under the positive list system is synthetic resin. For food contact utensils, containers and packaging using synthetic resin, the importer needs to confirm whether the base materials and additives are included in the applicable positive list.

This does not mean that other materials are completely outside food sanitation control. Metals, glass, ceramics, paper and other materials may still be subject to separate specifications, standards or safety checks under Japanese food sanitation rules. The positive list issue is especially important for synthetic resin, but food-contact suitability should be considered more broadly.

Why This Matters in Import Practice

This system often becomes a problem in import practice because the cargo is not food itself. Importers, shippers or forwarders may wrongly assume that food sanitation rules are irrelevant to kitchenware, packaging, novelty containers or machinery parts.

However, if the product is intended to touch food, the Japanese-side importer may need to submit an import notification and provide material information, test reports or compliance evidence to the quarantine station.

Points to Check Before Import

Before shipment, the importer should confirm whether the product has any food-contact use and whether synthetic resin is used in the food-contact part.

Key points include:

• whether the product is intended to contact food;
• whether synthetic resin is used in the food-contact surface;
• whether the base material is listed in the positive list;
• whether additives used in the material are listed or otherwise acceptable;
• whether the use conditions and temperature range are appropriate;
• whether test reports are available;
• whether material certificates are available;
• whether the manufacturer can provide compliance information;
• whether import notification of foods and related products is required.

If the invoice or product description is not enough to determine compliance, additional documents may be requested.

Information Transfer

Information transfer is central to this system. The Japanese-side importer cannot confirm compliance unless the overseas manufacturer or supplier provides reliable information about the material, food-contact surface and applicable standards.

Important information may include:

• material composition;
• identification of the food-contact part;
• positive list compliance information;
• test reports or certificates;
• intended use and use conditions;
• temperature range;
• manufacturer details.

A simple catalogue statement such as “food safe” or “for food use” may not be enough. Japanese import practice often requires more specific evidence, such as material certificates, compliance declarations or test reports.

Documents Commonly Needed

For first-time imports or new suppliers, the following documents should be collected before shipment whenever possible:

• product catalogue;
• product photos;
• material certificate;
• positive list compliance certificate or declaration;
• information on the food-contact surface;
• test report;
• documents showing use conditions;
• manufacturer information;
• invoice;
• packing list.

For synthetic resin products, it is especially important to identify which part touches food and what material is used in that part.

Practical Points for Forwarders

Forwarders and customs brokers do not usually determine technical compliance by themselves. However, they often become involved when clearance is delayed because the necessary material documents are missing.

Products that require particular care include kitchenware, food containers, plastic packaging, food bags, novelty containers, food-contact machine parts and imported samples intended for food-related use.

Before arranging shipment, it is safer to check whether the product has food-contact use, whether synthetic resin is used, and whether certificates or test reports are available. This simple confirmation can prevent arrival-side delays in Japan.

Common Problems

Typical problems include:

• the food-contact use was overlooked;
• synthetic resin use was not confirmed;
• the importer could not obtain a material certificate;
• positive list compliance could not be confirmed;
• the test report did not match the imported product;
• use temperature or use conditions were unclear;
• the cargo arrived before the importer collected the required documents;
• the shipper treated the item as ordinary miscellaneous goods.

If the required information is missing after arrival, the import notification review may stop. This can lead to additional document requests, testing, customs clearance delay, storage charges, return shipment or disposal.

Inspection and Sales-Stage Issues

Positive list compliance is an import-stage and food sanitation issue, but it does not automatically clear every sales-stage requirement. Labeling, advertising claims, instructions for use, temperature restrictions and product safety descriptions may need separate review depending on the product.

For overseas suppliers, it is important not to treat Japanese import clearance as a general approval for all retail claims or marketing expressions.

Formal Rules and Actual Practice in Japan

In Japan, even a simple plastic container or kitchen product may require detailed documentary confirmation if it is intended to contact food. Overseas suppliers may feel that requests for material certificates or compliance declarations are excessive, but in practice the Japanese importer often needs these documents to answer the quarantine station, customs broker, testing body or customer.

Origin-side forwarders can help by explaining that “food contact” is the key trigger. The question is not whether the cargo is food, but whether the product will touch food in Japan.

Key Takeaway

Japan’s Positive List System for food contact utensils, containers and packaging controls substances used in food-contact materials, especially synthetic resin materials. Products such as food containers, packaging films, kitchenware and food-contact parts may require confirmation even though they are not food themselves.

In practical import work, the safest approach is to confirm food-contact use, material composition, synthetic resin use, positive list compliance and test documents before shipment. Early confirmation helps prevent quarantine station delays, customs clearance problems, storage charges and additional costs in Japan.