Companies supplying food packaging and kitchenware can no longer rely on finished-product testing alone to demonstrate compliance in Japan, SGS advises. Under Japan’s Positive List framework, businesses must understand the polymers, monomers and additives used in regulated synthetic-resin food-contact materials and establish that the substances are authorized for the intended use.

Japan’s five-year transition period ended on May 31, 2025, and full Positive List requirements for food-contact materials within scope have applied since June 1, 2025. The framework reflects a broader regulatory shift towards substance-based oversight, placing greater emphasis on the composition of materials and the evidence businesses can provide across their supply chains.

One practical challenge is access to formulation information. Resin, additive and other upstream suppliers may treat details of material composition as commercially confidential, while downstream manufacturers, converters, brand owners and importers need sufficient information to assess compliance. Complex structures involving multiple layers, coatings, adhesives and barrier materials can add further difficulty, as can incomplete or inconsistent supplier documentation.

For companies operating internationally, the challenge is compounded by the need to manage different regulatory frameworks and substance lists across markets. While the specific requirements differ, positive-list approaches share an emphasis on substances being reviewed and authorized for food-contact use. Strong regulatory monitoring, supplier engagement and traceable documentation can help businesses identify gaps before products enter a market.

SGS recommends that companies build compliance processes that combine formulation reviews, supplier information gathering, documentation assessment and regulatory evaluation. These activities complement migration testing and other technical assessments, helping businesses understand whether the materials and substances used in a product meet the requirements that apply to it.

SGS solutions

SGS supports manufacturers and suppliers of food contact materials (FCM) with comprehensive testing and compliance services to help meet global regulatory requirements. With extensive technical expertise and international market experience, SGS helps ensure materials and articles intended for food contact comply with applicable territorial regulations.

SGS offers a full range of FCM testing services, including migration testing, alongside expert guidance on evolving regulations, compliance challenges and documentation review. Together, these services help organizations build comprehensive compliance strategies, strengthen supply-chain transparency and manage regulatory risks associated with market access. In the end, it’s trusted because it’s tested.