EU, China and Japan: how the rules for food contact materials are changing

When a company manufactures, purchases or imports packaging, utensils or plastic materials intended for food use, one of the first challenges is understanding that there is no single international regulatory system. Europe, China and Japan share the same objective: to ensure that food contact materials are safe, but they do so through different legal frameworks.

This is particularly important for companies importing products from Asia into the European market. Compliance with Chinese or Japanese regulations does not automatically mean compliance with European Union legislation. Comparing these three systems therefore helps to better identify requirements and the most common risks in import and export activities.

A common objective, but different models

In all three cases, the underlying principle is that a food contact material must not transfer substances to food in quantities that could endanger human health or bring about an unacceptable change in the food. However, the way this is regulated differs significantly.

• In Europe, the system is more harmonised for plastic materials, with Regulation (EU) No 10/2011 as the key reference. It establishes which substances may be used in plastic food contact materials, under what restrictions and with which migration limits. The system is also supported by good manufacturing practice requirements and a declaration of compliance.
• In China, the regulatory framework is built as a set of national technical standards. Standard GB 4806.1-2016 sets out the general requirements for all food contact materials, while GB 4806.7-2023 defines specific requirements for plastics. In addition, GB 9685-2016 covers authorised additives and GB 31604.1-2023 establishes general principles for migration testing.
• In Japan, the evolution has been somewhat different. The reform of the Food Sanitation Act introduced a positive list system for certain materials, particularly synthetic resins, bringing it closer to international regulatory models. The reform also strengthened good manufacturing practices and the obligation to provide compliance information throughout the supply chain.

In practice, what makes the difference is not only which substances are authorised, but how compliance is demonstrated and what documentation is required in each market.

Europe: a highly structured system for plastics

From a practical perspective, Europe is often the most familiar system for exporters. Regulation 10/2011 follows a clear logic: for plastics, it is not enough for a material to “appear safe”; it must be demonstrated that the substances used are authorised and that the product complies with the applicable migration limits. Compliance is demonstrated through a declaration of compliance, which must be available at all stages of the supply chain.

This makes the European system particularly documentation-heavy and technical. Companies must understand the material composition, the real conditions of use and the necessary testing to justify compliance. For importers from third countries, this is critical: often the issue is not only the material itself, but the lack of sufficient documentation to demonstrate compliance.

China: a technical and highly standardised system

China has developed a detailed and increasingly comprehensive system. The general standard GB 4806.1-2016 defines what constitutes food contact materials and articles and includes core principles such as safety, traceability and product information.

For plastics specifically, GB 4806.7-2023 requires that resins used must be permitted, additives must comply with GB 9685, and the material must meet technical requirements such as overall migration, certain specific migration limits, maximum content limits and sensory requirements. In addition, if the product uses inks, coatings or adhesives, it must also comply with the relevant standards for those components.

Another key aspect of the Chinese system is that testing must, as far as possible, reflect real conditions of use. Standard GB 31604.1-2023 requires appropriate simulants and test conditions to be selected based on intended use, applying the most severe relevant conditions.

In practice, this means that China does not rely on a single regulation, but on multiple standards that must be read together, which can make conformity assessment more complex.

Japan: the transition to a positive list model

Japan provides one of the most interesting examples in the regulation of food contact materials, illustrating how a country can move from a more flexible system to a much more controlled one. For years, safety relied on a negative list approach and industry self-regulation. However, this model became insufficient in an increasingly demanding regulatory environment.

The major shift came with the reform of the Food Sanitation Act, which entered into force in June 2020 and marked the transition to a mandatory positive list system, fully implemented in 2025. Under this new framework, the logic changes entirely: instead of allowing everything except what is prohibited, only substances that have been evaluated and approved by the competent authority—the Ministry of Health, Labour and Welfare (MHLW)—may be used.

One of the most relevant aspects of this reform is that the positive list was first introduced for synthetic resins, a key element in packaging, utensils and multilayer materials. In practice, this brings Japan closer to regulatory models such as those in the EU or China, where prior control of substances plays a central role. Nevertheless, Japan retains its own characteristics, as implementation has been gradual and not identical across all material types.

What happens if you import products from China or Japan?

This is where the comparison becomes most practical. A European company sourcing packaging from China or Japan should not only consider whether the product complies with the regulations of the country of origin, but whether it can demonstrate compliance in Europe.

The comparison between the EU, China and Japan shows that all three systems aim to protect food safety, but they do not speak exactly the same regulatory language. For companies importing from Asia, the key takeaway is simple: compliance at origin does not always mean compliance at destination. The most effective approach is to translate these differences into a control strategy—understanding composition, reviewing documentation, validating intended use and verifying compliance with the legislation of the target market.