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WTO Notification Content.
The draft Positive List was notified to the WTO on August 9, and comments will be accepted until October 8, 2019. The notification contains the following lists of proposed clearances for food-contact substances:
- Base Polymers (plastics)
- Base Polymers (coatings, etc.)
- Minor Monomers that may be used in base polymers
The lists of permitted base polymers (plastics), base polymers (coatings, etc.), minor monomers, and additives are available on the
MHLW website
. Each individual polymer listing details the food types that may be contacted (
e.g.
, acidic, alcoholic, fatty, etc.), the permitted temperature conditions of use, and any applicable limitations. The list of "base polymers (plastics)" details a total of 67 different base polymer categories, each classified among the 7 resin groups previously defined in the
evaluation guidelines
for food-contact plastics published by Food Safety Commission of Japan (FSCJ). For example, resin groups 5, 6 and 7 pertain to polyethylene (PE), polypropylene (PP) and polyethylene terephthalate (PET) resins, respectively.
The "Minor Monomers List" is a unique aspect of the proposed PL System, which designates the permitted monomers that can be used at up to 2%, alone or in combination.
- Additives, coating agents, etc.
The additive approvals specify the maximum use level for the substance in each of the aforementioned 7 resin groups, with additional limitations noted in the "remarks" column, where applicable.
Path Forward.
Nominations for plastic FCM (new substances or expanded clearances) will be accepted until October 8, 2019. Once reviewed, the final Positive List will be promulgated around December 2019 and take effect in June 2020. Substances subject to the PL System, but not included in the draft lists, will need to be the subject of formal petitions submitted to the Japanese government. The evaluation guidelines published by FSCJ make clear that these will be complex filings, and the time needed to obtain new clearances may be considerable.
Other FCM (
e.g.
, paper, adhesives, etc.) remain subject to MHLW's traditional regulatory scheme and the voluntary standards now in place. It is unclear when MHLW will take aim at its next Positive List expansion.
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