6. Japan

PCR Plastic Packaging Regulations
Global

6.1 Regulatory Overview

Food Contact Materials Safety is defined in Japan under Article 16 of the Japan Food Sanitation Law, Act No. 233 of December 24, 1947 [1] as following:

"apparatus or containers and packaging which contain or are coated with toxic or harmful substances and represent a risk to human health, or apparatus or containers and packaging which contact food, or additives which have a harmful effect on them and involve a risk to human health, shall not be sold, nor be produced or imported for the purpose of marketing, nor be used in business."

The same Article is also applicable to recycled plastics packaging. However, specific regulations covering specific requirements for post-consumer recycled plastics do not exist, and it is expected that these recycled materials meet the same safety characteristics of the corresponding virgin synthetic resins and are therefore regulated by the same legislation. 

In 2012, the Ministry for Health, Labour, and Welfare issued Guidelines for the use of recycled plastics in food applications, containers and packaging (Notice No. 0427 Article 2 of the Department of Food Safety) [2]. The Guidelines apply to all types of polymers and processes (mechanical and non-mechanical such as feedstock recycling and chemical recycling) and set out the principles for input control and safety determination of the finished products. A challenge test, similar to those used in EU and USA, is described to demonstrate the efficiency of the cleaning process; additional model contaminants are, however, indicated in the guidelines. Functional barriers are also included in the Guidelines.

In June 2020, a new legislation has been adopted in Japan for food contact materials, including plastics, based on a positive list system [3]. Recycled plastics are not explicitly regulated under this new legislation. However, the requirements set forth in this 2020 legislation also apply to recycled plastics.

Notice No. 0427, however, remains the official measure addressing recycling in Japan.

Japan - Regulatory Landscape

6.2 References

1. Food Sanitation Act (japaneselawtranslation.go.jp)

2. https://www.mhlw.go.jp/file/06-Seisakujouhou-11130500-Shokuhinanzenbu/pura.pdf (Japanese only)

3. positive list system for food appliances, containers and packaging (mhlw.go.jp)