Ministry of Health, Labour and Welfare (MHLW), In October 2025 (Reiwa 7), the Food Sanitation Standards Review Division of the Health and Life Hygiene Bureau proposed amendments to the Monomers, etc. Constituting Base Materials Specified in Table 1, Annexe 1 of the Specifications and Standards for Foods, Food Additives, etc. (Notification No. Kenshokuki-hatsu 1130 No.1, November 30, 2023) and the Guidelines on the Use of Recycled Materials as Raw Materials for Synthetic Resins Used in the Manufacture of Food Utensils and Containers and Packaging (Joint Notification No. Kenshokuki-hatsu 0328 No.7 and Kenshokan-hatsu 0328 No.7, March 28, 2024), following approval at the Utensils, Containers and Packaging Subcommittee meeting on September 29, 2025. Purpose (Section 1): Under the Positive List (PL) system per Article 18(3) of the Food Sanitation Act (Act No. 233 of 1947), synthetic resin-based food utensils, containers, and packaging (UCP) are prohibited unless meeting established specifications. The amendments enable physical recycling of polyolefins (polyethene and polypropylene) from post-consumer materials in food-contact applications, promoting safety and circularity. Public comments are solicited for these subcommittee-approved changes. Content (Section 2): As detailed in Annexe 1 (Proposed Amendment to Monomers Notification) and Annexe 2 (Proposed Amendment to Recycling Guidelines). Annexe 13 (Polymers Mainly Composed of Alkenes) adds Physical recycling treatment as an optional chemical treatment, limited to polymers with ?50% ethylene or propylene. Legal Basis (Section 3): Article 18(1,3) and Article 52(1) of the Food Sanitation Act; Article 66-5(2) of Enforcement Regulations (Ministry of Health Ordinance No. 23, 1948); Specifications and Standards for Foods (Ministry Notice No. 370, 1959), Section 3 UCP, A. General Specifications Item 8. Issuance and Application (Section 4): Issuance in Fiscal Year Reiwa 7; effective upon issuance. Guidelines Chapter 1 (General Provisions): Purpose: Ensure the safety of recycled material-based UCP via PL compliance and manufacturing controls to prevent sanitation hazards. Definitions: Recycled Materials (reprocessed from recovered materials per JIS Q 14021); Recovered Materials (collected waste alternatives to virgin materials); Virgin Materials (unprocessed per JIS Z 0130-4); Physically Recycled Polymers (from post-consumer via physical recycling, excluding pre-consumer); Physical Recycling (mechanical process: removal, crushing, washing, impurity separation, optional high-temperature/vacuum treatment); Chemical Recycling (decomposition to monomers, purification, repolymerization); Reuse (collecting/repurposing used products per JIS Z 0108); Post-consumer Materials (household/commercial waste per JIS Q 14021); Pre-consumer Materials (manufacturing waste excluding reusable scrap); Contaminants (unintended foreign substances or agents in recovered materials).These updates facilitate sustainable polyolefin recycling while upholding food safety under Japan's Food Sanitation Act.
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