Problems relating to Trade and Investment on France

22. Environmental pollution and waste disposal
Issue	Issue details	Requests	Reference

(1) Positive Listing of Food Manufacturing/ Processing Enzyme

- Turning food manufacturing/processing enzyme into positive list.

- It would seem its promulgation is due in 2020. Member firm is collecting information as it uses substantial enzymes in fabricating Japanese "Sake". Member firm considers it essentially important to have prior consultation between EU and Japanese enterprises including not only sake breweries, but also food processors/producers, etc. Concerned parties are collecting information.

- EU Directive No.23/2012

(2) Environmental Hormone BPA Control

- Due to the Bisphenol A (BPA) contents in the raw materials for the bottle caps manufactured by all firms that a member firm purchases from domestically in Japan, the December shipment destined to France has been canceled. Plural bottle cap manufacturers that a member firm sources bottle caps from are unprepared as yet for commercial production of totally BPA free caps. Caps, without BPA contents at the contact point with the liquid, can be substituted without substantial cost increase. However, French regulation makes no specific mention to the effect: "the caps are acceptable so long as the area touching the liquid surface does not contain BPA". The views are divided among manufacturers. The member firm, following its internal compliance programme, exercises self-control and refrains from export to France.

- As of today, the restrictions concern France. However, it is highly probable they get adopted all across EU. It remains unknown if chemical (scientific) verification, etc. have taken place on the degree of its impact upon human health (damage to health from intake of estimated amount of BPA for a determined period), etc., urging control. It seems unreasonable to apply the regulation on all across food products. Substantive, scientific ground for the measures is requested.

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