In Japan, it is common for manufacturers to outsource the production of food packaging to companies outside their direct jurisdiction, and there have been past cases of food safety issues arising from packaging that did not meet safety and quality standards. It makes things complicated.
In order to remove any ambiguity regarding the extent of liability in such cases, Japan's Ministry of Health, Labor and Welfare (MHLW) has decided to attribute ultimate responsibility directly to food manufacturers and to issue notifications containing specific clarifications of such issues. has been published. final product.
“Container and packaging tasks are often outsourced to other companies, but the final decision on whether to use packaging for food or beverages is usually left to the food manufacturer that initially outsources the work. ”The Ministry of Health, Labor and Welfare stated this through an official statement.
“In such cases, this final outsourcing company will be responsible for compliance with all necessary specifications and manufacturing practices, including compliance with the Consumer Affairs Agency (CAA) Positive List.
“If the outsourcing company is a sales-oriented company that does not have manufacturing facilities along the production chain and is not involved in the final stages of manufacturing the final product, then the liability lies with the company that manufactures the final product.” [to ensure this compliance]”
As an example, in the production of ready-to-drink milk coffee products, it is up to the company that puts together the entire final drink to ensure that the bottles and caps used to contain the drink comply with the following standards: It will be your responsibility. We adhere to all required safety and quality standards and are not the company that manufactured the bottle or cap, or the sugar, milk, or coffee powder used in the final RTD beverage.
The Positive List is a list of substances that are permitted to be used in food and drink packaging, and the regulations governing this essentially prohibit all other substances or materials from being used for this purpose. I am.
“However, in recent years, there has been significant division and decentralization of food and beverage manufacturing processes in order to improve efficiency, and there may be many variations in the process.”the ministry said.
“One important rule to keep in mind is that if a company manufactures a product for use outside the food system, such as a garden hose, it must not produce equipment, containers, or packaging that may come into contact with food. This means that they must not be involved in the manufacturing of
Concerns about notifications
The Ministry of Health, Labor and Welfare also emphasized that all food packaging companies are now required to submit notifications to local governments before starting production of food-related packaging.
This is a regulation that applies across the board to packaging companies involved in containers, packaging and food utensils, with the result that there may be more than one such company for an individual food product.
“When food packaging is divided into individual parts” [such as the bottles and bottle caps example above]Each part may be manufactured by a different company. ” That said/
“It is imperative that companies manufacturing each individual component not only comply with all necessary standards but also notify the Ministry.”