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 the Japan's Food Sanitation Act and the self regulatory industry organizations including Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA)
Registered Japan agent to manage your compliance as a registered trade member and to handle inbound/outbound communications with the local counterparties
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 growth despite the maturing economy.
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 voluntary standards of the trade organizations. In June 2020, the revised Food Sanitation Act adopted the Positive List (PL) compliance system regulating polymer materials used in manufacturing UCP products for Japan. This change brought the national rule in line with the existing PL system of private sector standards as well as those of EU and the U.S.
Consequently, the voluntary rules of trade organizations that issue product certifications are also being updated. This applies to the entire supply chain of the materials, such as resins, additives, intermediate materials, and final UCP products.
 “2019 & 2017 Packaging Material Trend and Outlook”, Fuji Keizai Group
Foreign manufacturers of food 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 can be obtained from a trade association such as JHOSPA as its member
Certification by a self-regulating trade organization is designed to protect product IPs from competitors, suppliers, and customers while asserting the safety and quality standards of your products for customers
JHOSPA membership requires foreign firms to have a Japan-based registered liaison who can be a 3rd party agency such as Skylands
Its membership must be active to maintain product certifications
All inbound/outbound communications with JHOSPA are conducted in Japanese
Government announcements and publications of rules are limited and often delayed in English
Relying on suppliers or customers as your liaison might risk potential conflict of interests in your product IPs, informational delay, and independent control of your compliance matters
Skylands Global can mitigate these risks in managing your compliance as your registered agent
Questions can be directed to:
The information on this website is provided solely for informational purpose and does not constitute legal advice.