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Revision of Japan Food Sanitation Law

May. 11 2026

In May 2025, Japan published Cabinet Office Notification 95/2025 regarding a partial revision of the Specifications and Standards for Foods, Additives, etc. (‘Apparatus and Containers/Packaging’ under MHLW Notification No 370 of 1959) under the Food Sanitation Act (Japan Food Sanitation Law (JFSL), Act No. 233 of 1947). The revised methods and specifications will become effective on June 1, 2026. Food contact apparatus, containers and packaging may comply with previous provisions if sold, manufactured or imported for sale or business use before June 1, 2027.

Requirement Summary and Effective Dates:

The key change is in Section 3 Clause D, where for General Synthetic Resins the requirement for Potassium Permanganate (KMnO4) consumption has been replaced by an Overall Migration with a limit of ≤ 0.1 mg/cm². The KMnO4) consumption test remains in place for other materials, such as listed plastics with specific requirements in the Act.

The table below lists the simulants used in the migration; the overall migration uses solvents other than just water to simulate different conditions.

Food Type

Simulant used

Fats, Oils, Fatty foods, Creams

Heptane

Alcoholic beverages, milk*

20% ethanol

Acidic food other than oils, fats, fatty foods, cream, alcoholic beverages, and milk*

4% acetic acid

Foods other than those mentioned above

Water

*Milk here refers to milk, special milk, pasteurized goat milk, adjusted milk, low-fat milk, non-fat milk, processed milk, liquid preparation milk, fermented milk, lactobacillus beverages, milk beverages and adjusted milk powder.

Many additions and removals have been made to multiple clauses of Section 3, including Clause B on ‘General Test Methods for apparatus, containers, and packaging’ and Clause D on ‘Material Standards for utensils, containers, and packaging, or the raw materials thereof’.

For full details of changes beyond the new Overall Migration requirement, please see the original text.

For more information, see text of 
器具・容器包装、おもちゃ、洗浄剤https://www.caa.go.jp/policies/policy/standards_evaluation/appliance/

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