Japan MRLs & Food Safety Laws

Introduction to Japan MRLs

Japan Maximum Residue Levels (MRLs) are established by the Ministry of Health, Labor, and Welfare (MHLW) under auspices of the Food Sanitation Law. Over the years, specific withholding limits (WHLs) have been set under the Agricultural Chemical Control Law to govern residue limits associated with approved Good Agricultural Practices (GAP), but these were applicable only for domestically grown agricultural commodities. In a number of cases, import MRLs have been established by MHLW to govern the residue levels on imported food commodities. These import MRLs may be based on reference to Codex, U.S., or other scientifically-established standards. For crop/pesticide combinations for which import MRLs have not been established, no specific regulation of pesticide residues is currently in force (i.e., if no standard exists, there is no standard to violate.) A total of approximately 230 pesticide active ingredients currently have MRLs established under the Food Sanitation Law, and an English-version listing is maintained on the Web site of the Japan Food Chemical Research Foundation.

Methods of Establishing, Enforcing MRLs Changing

Japan has now changed the way it establishes and enforces chemical residue standards, based on the Food Safety Basic Law enacted in 2003. This legislation mandates:

  • A “positive-listing” approach for regulation of pesticide residues in all foods;
  • Import of food into Japan with detectable pesticide residues only if a specific Japan MRL has been established; and
  • New food uses to be approved only in association with establishment of specific MRLs.

The legislation took take effect in May 2006, and after publishing several preliminary lists for public/industry comment, MHLW published the final listing of provisional MRLs for all crop/pesticide combinations. Establishment of these provisional MRLs was based on:

  • Existing Japan WHLs;
  • Codex MRLs; or
  • Scientifically established MRLs from Australia, Canada, EU, New Zealand, and U.S. (in this order of preference.) For pesticide/crop combinations without a specific MRL, the default MRL of 0.01 ppm will be applicable.

In the future, a risk evaluation process will be employed to convert the provisional MRLs into permanent ones.

Given the critical place of Japan in major food trade relationships with partners including the U.S. Australia, China, and others, Japan MRLs are important especially in light of the future transition to a positive listing system.

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