The Positive List System
This is a system to prohibit the distribution of foods that contain agricultural chemicals above a certain level.
The system was implemented on May 29, 2006, following the revision of the Food Sanitation Law.
All agricultural chemicals, veterinary drugs and feed additives in all kinds of foods, including processed foods, are subject to regulation.※
The distribution of foods which contain agricultural chemicals in excess of the determined residue limits is banned in principle.
※Some specified substances are exempt from the regulation.
1.The uniform limit
The uniform limit is set at 0.01 ppm,※which was determined by the Ministry of Health, Labor and Welfare as a volume that is not likely to pose any adverse health effects.
※0.01 ppm indicates a concentration that is roughly equivalent to the concentration of a 25 meter-swimming pool containing a few drops of a pesticide.
2.Provisional residue limits
These are provisionally established limits, referring to Codex standards, among others.
Before the enforcement of the Positive List System
| |
rice (unmilled rice) |
soybeans
|
onion
|
| agricultural chemicals A
|
0.5ppm |
1.0ppm |
Exempted substances |
| agricultural chemicals B
|
Exempted substances |
0.05ppm |
Exempted substances
|
| agricultural chemicals C
|
Exempted substances |
Exempted substances
|
0.1ppm |
After the enforcement of the Positive List System
| |
rice (unmilled rice) |
soybeans
|
onion
|
| agricultural chemicals A
|
0.5ppm |
1.0ppm |
0.1ppm
Provisional residue limits |
| agricultural chemicals B
|
0.01ppm
uniform limit |
0.05ppm |
0.01ppm
uniform limit |
| agricultural chemicals C
|
1.5ppm
Provisional residue limits |
0.01ppm
uniform limit |
0.1ppm |
1. Not only perishable, but also processed foods are subject to regulation.
When residue limits are not established, the uniform limit is applied in principle; however, when residual values of ingredients for processed foods comply with the limit.
2. As for processed foods such as dried foods, the probability of violation for ingredients according to the estimated value based on moisture content can be suggested.
Consider a case in which there is an apple orchard next to the field where carrots are grown, and fenbuconazol used in the apple orchard drifted from the orchard to the carrot field.
While the residue limit of fenbuconazole in apples is set at 1 ppm, the residue limit of the pesticide in question in carrots has not been determined. Therefore, the uniform limit is applied to corrots, and the limit becomes 0.01 ppm.
1. Inspections conducted by the nation (monitoring inspections, mandatory inspections, etc.)
Importers submit the “Notification Form for Importation of Foods” to the Ministry of Health, Labor and Welfare via a quarantine station, and the food in question is screened to determine whether it is in conformity with the Food Sanitation Law by food sanitation inspectors from a quarantine station.
【Monitoring Inspections】
This is an inspection performed at a quarantine station for food with a low probability of violating the Food Sanitation Law. It is based on the annual plan, taking seriousness of problems into consideration such as volumes, number of violation cases, and violation rate by food type. This inspection aims at grasping the sanitary conditions of a wide variety of imported foods, along with promoting a smooth import and distribution process. Thus, importers can go through import procedures without waiting for the test results.
【Administrative Inspections Other Than Monitoring Inspections】
Quarantine stations conduct inspections of first-time imported foods, confirmatory tests of food against the Food Sanitation Law, confirmatory inspections of damaged food in transit, etc.
【Mandatory Inspections】
These are inspections performed by an importer by an order of the Ministry of Health, Labor and Welfare for food which is considered to have a high probability of violating the Food Sanitation Law, taking into account foreign exporter’s national circumstances, the properties of the food in question, and the previous cases in which a same type of food have not been approved. Naturally the inspection cost is born by the importer. Importers cannot begin import procedures until the food is proved to be in compliance with the law.
2.Inspections Performed by Prefectures (Random Sampling Inspections and On-Site Inspections)
As for domestically manufactured or sold food, public health centers and wholesale food market sanitary inspection stations collect the necessary amounts of foodstuffs concerned for inspection from production facilities or distribution outlets based on their annual plan. ※When a violation is discovered, the foodstuffs concerned are discarded and/or recalled. When facilities for production, manufacturing, and processing are in locations separate from the inspected site, the inspectors in charge contact the prefectures and municipalities concerned and take necessary measures immediately, all working in tandem.
※According to the publication, “2007 (FY) Fukuoka Prefecture’s Food Sanitation Monitoring Guidance Plan,” the prefecture plans to inspect approximately 100 samples for the year (200 residual agricultural chemicals).
【Random Sampling Inspections】
These inspections are conducted by municipalities based on their monitoring guidance plan to confirm the safety of foodstuffs which are manufactured and distributed in the area under their jurisdiction.
【On-Site Inspections】
These are inspections conducted for food-related business facilities based on an on-site inspection plan.
When agricultural chemicals or other substances are found in excess of the determined level, administrative penalties such as guidance for improvement, discontinuation of sales/shipments, and recall of the relevant lot are imposed on the facility concerned.
【Violation Cases Discovered by Prefectures】
- 0.44 ppm of fosthiazate (determined acceptable level: 0.05 ppm) remained in strawberries. The berries were voluntarily recalled and the shipment was discontinued.
- 0.07 ppm of heptachlor (determined acceptable level: 0.03 ppm) remained in pumpkins. The shipment was temporarily discontinued, and the in-stock pumpkins were all incinerated after being voluntarily recalled.
【Our Perspective】
Since the enforcement of the Positive List System enacted on May 29, 2006, there has been a sharp increase in violation cases.
The violation cases in FY 2006 totaled as many as 425, a figure which is 6.43 times higher than the last year. Violation of the uniform limit (0.01 ppm) in the system amounted to 205 cases, which accounts for approximately 48% of the total.
Therefore, we believe that producers and importers need to implement a more stringent quality control management system.
