Japan Seeks Public Comments on Two Amendments Regarding the Use of Recycled Materials in Food Contact Applications

Japan is moving to strengthen its food contact materials regulations and support a circular plastic economy. On October 17, 2025, Japan’s Consumer Affairs Agency, through its Food Sanitation Standards Review Section, launched a public consultation on two draft amendments under the Food Sanitation Act. The proposed revisions update Japan's positive list system for food packaging materials and provide new regulatory guidance for the use of recycled plastics – specifically, physically recycled polyethlene and polypropylene – in food utensils and container packaging.

 The drafts include updates to Monomers and Other Starting Materials Specified in Table 1 of Appendix 1 of the Standards for Foods, Additives, etc, and the Guidelines for the Use of Recycled Materials as Raw Materials in the Manufacture of Food Utensils and Container Packaging. These changes aim to formally incorporate recycled polyolefins into the compliance framework and establish clear quality management and corporate responsibility requirements for businesses using recycled materials in food-contact products.

Background

These revisions are based on the positive list system established under Article 18, Paragraph 3 of the Food Sanitation Act. Under this system, the use of synthetic resins as the primary material in food packaging is prohibited, except where the substances contained in the raw materials meet specific standards.

On September 29, 2025, the Committee on Utensils and Container Packaging under the Food Sanitation Standards Council formally approved the inclusion of physically recycled polyethylene and polypropylene within the compliance scope. The current amendments aim to translate this approval into specific regulations, offering clear operational guidelines for relevant businesses.

Main Revisions in the Drafts:

Draft One: Revision to Monomers and Other Starting Materials Specified in Table 1 of Appendix 1 of the Standards for Foods, Additives, etc.

• Update to the Positive List: Under the table for Polymers with olefins as the main monomers, a new category Physical Recycling Process has been added as a type of Any Chemical Treatment. This physical recycling process is limited to treatments on the components of the polymer and is applicable only to polymers with more than 50% ethylene or propylene content (i.e., polyethylene and polypropylene).

Draft Two: Revision to Guidelines for the Use of Recycled Materials as Raw Materials in the Manufacture of Food Utensils and Container Packaging

• Unified and Clear Definitions: The original guideline's definition of polymer processed through physical recycling has been removed. The definition of Physical Recycling Process now clearly categorizes it as a type of chemical treatment permitted under the positive list.
• Enhanced Corporate Responsibility: It is explicitly stated that businesses using physically recycled materials to manufacture food packaging must assume ultimate responsibility to ensure that their raw materials are suitable for food use. Materials that have undergone complex post-consumer processing or cannot be confirmed to meet the positive list are not applicable for physical recycling.
• Establishment of a Quality Management System: Businesses are required to strictly manage contaminants in recycled materials, focusing on the quality and selection of recycled materials, the recycling process, the ability to remove contaminants, the specifications of food packaging made from recycled materials, and their limited use, ensuring that the final products fully comply with the Food Sanitation Law.

This revision marks a significant step in Japan’s efforts to promote a plastic recycling economy and ensure food hygiene safety. The public can submit feedback through the official website until November 17, 2025.

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Further Information

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