Overview of Japan’s Amended Positive List for Synthetic Resins
Since Japan’s Ministry of Health, Labour and Welfare (MHLW) introduced the Positive List (PL) of substances permitted for use in “synthetic resins” used in utensils, containers and packaging (UCP) effective from June 1, 2020, the Japanese authorities have continued working on the PL. The Amended PL was published by way of MHLW Notification No. 324 of 2023, [1] which took effect on June 1, 2025, and has undergone additional changes since then.
Structure
The Amended PL includes the following lists of permitted substances: [2]
- Table 1 – Base materials (polymers)
- Annexes – Monomers, etc.
- Table 2 – Additives
The most obvious change since the issuance of the 2020 version is that the Amended PL is now a monomer-based system, with its Table 1 listing the permitted types of polymers and the corresponding polymer groups, and the Annexes specifying the constituent components (essential monomers, optional substances, etc.) for each type of polymer. For example, “polymer mainly composed of alkenes as the main monomer” is listed on Table 1 under Polymer Group 2, and the corresponding constituent monomers and other components are listed in Annex 13. Notably, polymer listings under the Amended PL have removed the food type and temperature restrictions contained in the 2020 version of the PL.
The structure of Table 2 has remained largely consistent with the 2020 version of the PL. For each substance, the PL provides the Japanese chemical name, use limit by polymer groups, and other applicable restrictions.
Scope
Consistent with the 2020 version, substances such as those that are not intended to remain in the final product are not required to be listed on the Amended PL. The Amended PL has also removed the listings for inorganic substances, natural substances, etc. from its scope, resulting in the deletion of hundreds of substances from Table 2 of the 2020 version, such as talc, red algae, and many others. Although these groups of substances are no longer listed on the PL, they still may be used in UCP, but it remains the responsibility of the business operators to ensure their safety.
Recycled Plastics
The Amended PL for the first time specifies permitted types of recycled plastics, which are contained in the Annexes for the constituent components of polymers. In Annex 12 for polymers mainly composed of ester bonds, “mechanical treatment” is allowed, limited to “treatment of polymers in which the total amount of ethylene glycol and terephthalic acid is 50 mol % or more of the polymer's constituent components” (i.e., PET). Similarly, physically recycled PS is permitted in Annex 15. More recently, physically recycled PE and PP were authorized for food-contact use in Annex 13. These materials are subject to the revised guidelines on the use of recycled plastics in UCP, which were published on December 26, 2025. [3]
Functional Barrier
The functional barrier concept remains unchanged under the Amended PL. Substances that are not listed in the PL may nonetheless be used in food packaging applications, provided they do not directly contact food, their migration does not exceed 0.01 mg/kg (i.e., 10 ppb), and they are not genotoxic. The concept allows the use of these substances without the need for an explicit listing in the Amended PL, subject to the general safety requirement in the Food Sanitation Act.
Ongoing Review
As of April 1, 2024, the administration of food sanitation standards in Japan (including food, food additive, and food packaging standards) has been transferred from MHLW to the Consumer Affairs Agency (CAA). After the Amended PL was published on November 30, 2023, and took effect on June 1, 2025, the Japanese authorities have continued making changes to the listings; for example, the aforementioned clearance of mechanically recycled PE and PP.
Clearances for New Substances
On September 5, 2025, CAA published revised guidelines on procedural and data requirements for petitions to revise the listings of the PL. [4] Industry should follow the guidelines to apply for revisions to the PL upon prior consultation with the Food Sanitation Standard Evaluation Division within the CAA.
[2] The updated Tables and Annexes of the PL are available here.