1. Positive lists and new requirements since 2023
Since June 2025, the revised positive list system for plastics and additives has been in force in Japan. That means for packaging manufacturers and packers that only raw materials listed in the current lists may be used. It is particularly important to distinguish between the previous (2019) and new (2023/2025) lists, as groups and limit values have changed. Those issuing declarations of conformity should explicitly refer to the current version in order to avoid misunderstandings and complaints.
2. Conformity assessment: Observe both the previous and new systems in parallel
Conformity testing in Japan still requires both systems to be taken into account: in addition to the positive lists, the old specifications (e. g. heavy metal limits, potassium permanganate consumption, evaporation residue) must also be observed. Many companies overlook these requirements, but they remain mandatory if the customer requests comprehensive confirmation. In practice, it is advisable to adapt the analyses for heavy metals and migration to the Japanese requirements (e. g. 4 % instead of 3 % acetic acid).
3. Recycled materials and risk assessment
Post-consumer recyclates are currently only permitted for PET and polystyrene in Japan. The use of PCR material is not permitted by law for other plastics such as PE and PP. In addition, there is a clearly structured risk assessment system for non-listed substances or NIAS: those wishing to use new additives or degradation products can obtain approval on the basis of an exposure assessment and toxicological data – however, this involves a great deal of effort and the data requirements are strict.
Conclusion
For packaging manufacturers and packagers supplying the Japanese market, it is essential to use the current positive lists, to note the parallel validity of old specifications, and to be aware of the legal limits and assessment methods when using recycled materials or new additives.
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