ROHS Compliance

Japan’s Consumer Affairs Agency has announced revisions to the Specifications and Standards for Foods, Additives, and related materials, introducing important changes to the Positive List system for food contact materials, which was initially implemented in 2025. 

One of the key updates is the extension of the transition period. Previously, the new requirements were set to apply from June 1, 2025, with older standards allowed until June 1, 2027. The revised notice now extends the deadline to June 1, 2030, giving companies an additional three years to transition to the new regulatory framework. 

The revision also expands the scope of application. In addition to utensils, containers, and packaging already covered, the regulation now includes “similar items” manufactured using substances that were previously used in compliant products before or during the transition period. This allows manufacturers to continue producing comparable products using the same substances while still following the previous standards during the extended transition. 

Another update is the addition of precautionary provisions for testing and compliance. The new clause clarifies that testing institutions—such as public health institutes and quarantine stations—must ensure appropriate quality and precision control when conducting specification tests, particularly where evaluation of testing methods has not yet been fully completed. 

Overall, the revision aims to provide regulatory clarity and more time for industry adaptation, helping companies transition smoothly to the Positive List system while maintaining product safety and compliance.