FOOD CONTACT MATERIALS INDUSTRY
Skylands’ team of on-the-ground and cross-border consultants provides compliance support and product certification services for the Japanese market. We serve manufacturers and distributors of food contact materials (FCM), also called food utensils, containers, and packaging (UCP) materials. They include synthetic resins, additives, colorants, masterbatch, intermediate raw materials, and final UCP products.
Product certification and registration for the Positive List compliance under Japan's Food Sanitation Act and the self-regulatory industry organizations including Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA) and its successor JCII Food Contact Material Safety Center
Registered Japan agent to manage your product compliance requirements and to handle communications and relationships with local customers, suppliers, and regulators
In 2018, Japan’s consumer food/beverage sector was $779 billion, up 11%+ over 8 years (USDA Foreign Agricultural Service). Its food and beverage packaging market is estimated to reach US$19 billion in 2020 and to continue its solid growth.
The food packaging sector is expanding faster than the overall economy. Its growth is driven by the increasing consumption of single-serve, prepared foods due to the growing trends of single-member households, aging population, increase in women in the workforce, and popularity of eCommerce in consumer food distribution. 
The safety of food contact materials in Japan is governed by the national laws and the well-established voluntary standards of the country's trade organizations. In June 2020, the revised Food Sanitation Act adopted the National Positive List (PL) compliance system regulating polymer materials used in manufacturing UCP products for Japan. This welcomed change brought the national rule in line with the existing private-sector PL system as well as those of EU and the U.S. Both the NPL and private-sector PL standards now apply to manufacturers and distributors within the industry's supply chain of the food contact materials, such as resins, additives, intermediate materials, and final UCP products.
Starting in 4/2021, implementation of Japan's food contact material regulations along with the new compliance requirements and necessary product certification processes will be unified under a single trade institution, JCII Food Contact Material Safety Center.
 “2019 & 2017 Packaging Material Trend and Outlook”, Fuji Keizai Group
Foreign manufacturers of food contact and packaging materials should view Japan's new food safety regime as a renewed opportunity for business there.
Practical tips for entering the Japanese food contact material market:
Product certifications are the de facto standard required in trading food contact materials in Japan
Product certifications are issued by authorized trade associations such as JHOSPA and its successor JCII
Certification asserts that a product complies with the safety standards of both national and private-sector PLs
Having a neutral trade institute as an issuer of certificates protects product IPs from competitors, suppliers, and customers
JHOSPA/JCII membership requires foreign firms to have a Japan-based registered liaison who can be a 3rd party agency such as Skylands Global
Its membership must remain active throughout the valid life of its product certifications
All inbound/outbound communications and business with the trade institute are conducted in Japanese
Government announcements and publications of rules in English are often delayed and limited
Relying on suppliers or customers as your liaison may risk a potential conflict of interests in protecting your IPs, preventing informational delays, and ensuring independent control of your compliance matters
Skylands Global can mitigate these risks and help manage your compliance as your registered agent
Questions can be directed to:
The information on this website is provided solely for informational purposes and does not constitute legal advice.