Japan Revises Specifications and Standards for Food Contact Materials

SafeGuardSHardgoodsAug 07, 2025

SG 114/25

Japan has amended its specifications and standards for food contact apparatus, containers and packaging.

In May 2025, Japan issued Cabinet Office Notification No. 95 (Notification 95/2025, time limited for free viewing in the Kanpō (Official Gazette), Extra 119, 205) to partially revise the ‘Specifications and Standards for Foods, Additives, etc. (Ministry of Health, Labor and Welfare (MHLW) Notification No. 370 of 1959) under the nation’s Food Sanitation Act (also known as Japan Food Sanitation Law (JFSL), Act No. 233 of 1947).

Key amendments to the specifications and standards under Notification 95/2025 are summarized in Table 1.

Clause to Section 3 ‘Apparatus and Containers/Packaging’ under MHLW Notification No 370 of 1959	Highlights of amendment
B ‘General test methods for apparatus, containers and packaging’	Details methods for: Potassium permanganate consumption Chloroform soluble matter Atomic absorption spectrometry (AAS): standard solutions Heavy metals (expressed as lead) Evaporation residue Overall migration Arsenic (expressed as diarsenic trioxide), with a schematic diagram of equipment Formaldehyde 2-mecaptoimidazoline Inductively coupled plasma mass spectrometry (ICPMS) ICP-atomic emission spectrometry (AES) Clarifying the types of food for 20% ethanol as simulant under ‘Preparation of test solution for dissolution test’ (see Table 2 below) Glass, ceramic or enameled utensils, containers and packaging Synthetic resin utensils, containers and packaging Rubber implements, containers and packaging in relation to 1) non-nursing equipment and 2) breastfeeding equipment Metal cans
C ‘Reagents and solutions’	Details the reagents and their preparations for testing
D ‘Material standards for utensils, containers and packaging, or the raw materials thereof’	Specifies one distinct set of requirements with limit values for each of the following food contact article categories: Glass utensils, containers or packaging Ceramic utensils, containers and packaging Enameled equipment or container packaging Replaces the requirements for ‘Potassium permanganate consumption’ with ‘≤ 0.1 mg/cm² overall migration (excluding those with a defined individual specification)’ under general standards for synthetic resin utensils, containers and packaging Defines specifications for each of the following synthetic apparatus, containers, and packaging: Phenolic, melamine or urea resin Food contact materials (FCM) and articles using formaldehyde as a raw material (excluding those that use phenolic, melamine or urea resin as the main material)¹ Polyvinyl chloride (PVC)¹ Polyethylene (PE) and polypropylene (PP)¹ Polystyrene (PS)¹ Polyvinylidene chloride (PVDC)¹ Polyethylene terephthalate (PET)¹ Polymethyl methacrylate (PMMA)¹ Polyamide (PA)¹ Polymethylpentene (PMP)¹ Polycarbonate (PC)¹ Polyvinyl alcohol (PVA)¹ Polylactic acid (PLA)¹ Polyethylene naphthalate (PEN)¹ Rubber implements (excluding baby implements) or containers and packaging Rubber feeding utensils Metal cans, excluding those containing dried foods (excluding oils, fats and fatty foods)
E. Standards for use of apparatus, containers and packaging	Container packaging for containerized, pressure- and heat-sterilized foods (excluding canned or bottled foods) Standards for equipment for daily products (milk, dairy products and foods made primarily from these) Equipment used in making ice cream Food vending machines (limited to those having a structure in which food comes into direct contact with the components) and the containers used to sell food
F ‘Manufacturing standards for utensils, containers and packaging	Details the general safety requirements for, among other things, copper or copper alloy food contact articles
¹Must comply with ≤ 10 µg/mL potassium permanganate consumption as part of its individual standard

Table 1

Food type		Simulant
Fats, oils and fatty foods, and creams		Heptane
Alcoholic beverages, milk, special milk, pasteurized goat milk, adjusted milk, low-fat milk, non-fat milk, processed milk, liquid preparation milk, fermented milk, lactobacillus beverages, milk beverages and adjusted milk powder (hereafter referred to as ‘alcoholic beverages, etc.’ in this table)		20% ethanol
Foods other than oils, fats, fatty foods, cream and alcoholic beverages, etc.	Acidic food	4% acetic acid
	Foods other than those mentioned above	Water

Table 2

Cabinet Office Notification 95/2025 entered into force on June 1, 2025. The revised methods and specifications will become effective on June 1, 2026.

Food contact apparatus, containers and packaging may comply with previous provisions if sold, manufactured or imported for sale or business use before June 1, 2027.

Details of Cabinet Office Notification No. 95 of May 30, 2025 and Section 3 ‘Apparatus and Containers/Packaging’ (last revised by Notification No. 95/2025) are available on the Japan Consumer Affairs Agency (CAA) website.

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