Japan Food Sanitation Act: A Pre-Shipment Checklist for Food Contact Products

Use this checklist before you book a shipment of plastic food-contact items — containers, utensils, packaging — to Japan, so you can confirm your paperwork matches what the [Japan Food Sanitation Act](/regulations/japan-food-sanitation-act) requires.

1. **MHLW Food Sanitation Act Compliance Declaration** — Confirm your supplier can provide this declaration for the specific product and resin type you're importing, not a generic company-wide statement.

2. **Positive List substance verification** — Check that every resin, additive, and colorant used in the product appears on Japan's Positive List for the material category it's made from (for example, polyolefins versus PET have separate lists).

3. **Elution test results (30ppm limit)** — Get documented test results showing total elution from the plastic does not exceed 30ppm (30μg/ml); this is the core quantitative limit under the Positive List System.

4. **Factory inspection records** — Request the manufacturing site's inspection records to confirm the product was made under the conditions described in the compliance declaration, not just tested once in a lab.

5. **Match documents to the actual SKU** — Verify that the declaration, test results, and inspection records all reference the exact product code or formulation you're shipping, since substitutions or resin changes can invalidate prior paperwork.

6. **Keep copies before the goods leave the factory** — Collect and file all four documents before shipment, so you're not trying to source them after the container is already at a Japanese port.

7. **Reconfirm after any supplier or formulation change** — Treat a new resin supplier, colorant, or additive as a reason to repeat the Positive List verification and elution testing, even if the product name hasn't changed.

If any of these documents are missing or out of date, Japan Food Sanitation Act compliance for that shipment is not confirmed, regardless of how the product has cleared customs in other markets. Small importers and resellers often rely on supplier assurances alone, but the Positive List System puts the responsibility on verifiable testing and documentation, not just a label or invoice description.

Building this checklist into your supplier onboarding process, rather than treating it as a one-time check, is the more reliable way to handle Japan Food Sanitation Act requirements over multiple shipments. For ongoing tracking of supplier documents across products, see [supplier compliance](/supplier-compliance).

If you want help organizing these records before your next shipment, Complyra can walk through the checklist with you.