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With an efficient food distribution system in Japan, and emphasis on food safety and quality of packaging, Japan continues to be an attractive market for exporters of food products and food packaging materials. A critical component to marketing food products in Japan rests on ensuring that packaging materials comply with the regulatory scheme in place for food-contact materials.
The Japanese regulatory framework for food packaging materials combines government regulations based on the Food Sanitation Law of 1947 and industry standards that have been established by industry trade associations. The Japanese Food Sanitation Law sets out a general safety standard that covers not only food, but also food additives, food packaging materials and equipment, detergents for vegetables and fruits, eating utensils, and toys for young children. Regarding food-contact materials, the legislation prohibits the sale of equipment or packages containing toxic or harmful substances that could be deleterious to human health. In addition, the Food Sanitation Law includes an enforcement component that includes inspection of domestic food-business facilities, import notification requirements, monitoring and testing requirements, and the imposition of penalties.
Food Sanitation Law Specifications
While Japan presently does not have a "positive list" of substances that are permitted for use in articles that contact food or require premarket approval or review of food-contact substances prior to their use in the marketplace, the Food Sanitation Law authorizes the establishment of specifications for food containers and packaging, and the raw materials used to manufacture such articles. The Japanese Ministry of Health, Labour, and Welfare (MHLW)-under the Pharmaceutical and Food Safety Bureau, Department of Food Safety, Standards and Evaluation Division-is responsible for developing such specifications. To date, three different types of specifications for containers and packaging materials have been established: (1) general specifications that apply to all containers and packaging; (2) material-specific standards; and (3) certain specifications that apply to the end-use application for the packaging.
The general specifications that apply to all food containers and packaging materials primarily address the use of certain metals, particularly lead, in various food contact applications. The specifications also prohibit, for example, the use of di(2-ethylhexyl) phthalate as a plasticizer for polyvinyl chloride (PVC) used in contact with foods containing edible fats and oils. As for colors intended for use in packaging materials,...