How are maximum residue limits set? Japan’s positive list system and how much we actually eat
How limits are derived from the ADI, and how much people take in from everyday meals
In short
MRLs are set food by food, based on the concentration that remains when the pesticide is used as directed, so that the intake calculated from how much of that food Japanese people eat does not exceed the ADI or ARfD. For pesticides with no MRL, the sale of foods in which more than a uniform 0.01 ppm remains is prohibited (the positive list system, since May 29, 2006).
In a survey that analyzed actual everyday meals, intake was 0.477% of the ADI for the highest ingredient (Consumer Affairs Agency, fiscal 2024).
Who decides what
| Role | Responsible body | What it decides |
|---|---|---|
| Assessing safe amounts | Food Safety Commission of Japan (FSCJ) | ADI (acceptable daily intake: the amount that has no effect even if taken every day for a lifetime) and ARfD (acute reference dose: the amount that has no effect even if taken at one time) |
| MRLs for each food | Consumer Affairs Agency (since April 2024; before that, MHLW) | Maximum residue limits, decided after deliberation by an advisory council |
| Rules for use | MAFF | Registers each pesticide with the crops, amounts, number of applications and days before harvest set so that residues meet the MRLs (→ Do pesticides differ by crop?) |
| Inspection | Local governments and quarantine stations (MHLW compiles the results) | Testing of food on the market |
How MRLs are set
- Draft an MRL based on the concentration that remains in the crop when the pesticide is used as directed (crop residue trials). If there is a Codex (international food standard) limit, it is taken into account.
- Multiply by the amount of each food that Japanese people eat to calculate the daily intake.
- Long-term consumption: confirm that the calculated amount does not exceed the ADI (in MHLW's 2015 briefing materials, “80% of the ADI or less”; the remaining 20% allows for intake from sources other than food, such as water and the environment).
- Eating a lot at once: confirm that the ARfD is not exceeded (introduced step by step from fiscal 2014).
- Check not only for the national average but also for young children, pregnant women and older people.
Example: in the subcommittee report on chlorantraniliprole (November 2025), estimated intake was 1.5% of the ADI for the whole population and 2.6% for young children.
The positive list system and the uniform limit of 0.01 ppm
- Since May 29, 2006, the sale, import and so on of foods in which a pesticide or similar substance with no MRL remains above 0.01 ppm has been prohibited. This applies equally to domestic and imported products.
- The 0.01 ppm figure was derived by taking 1.5 μg per day as a guideline for an amount of a single pesticide that is safe to take in, and working backward from how much food Japanese people eat (enforcement notice).
- MRLs currently exist for 760 items (Consumer Affairs Agency). Seventy-seven substances that are “clearly not likely to harm human health,” such as copper, sulfur, baking soda and machine oil, are excluded.
What people actually eat (market basket survey)
The Consumer Affairs Agency buys food at supermarkets and elsewhere, combines it in the proportions of an ordinary diet, cooks it and analyzes it (fiscal 2024: 8 regions × 14 food groups, 47 pesticides etc.). Nineteen pesticides etc. could be quantified, and their shares of the ADI were as follows.
The other 28 pesticides etc. could not be quantified in any sample. The range (lower–upper) reflects whether samples in which a pesticide could not be quantified are counted as 0 or as the limit of quantification. The ADIs used in the survey were the values at the time (thiamethoxam was 0.018; it is now 0.012).
Share exceeding the MRL (fiscal 2024)
The number of tests is the total of “pesticide × sample” combinations. For details, see Pesticides detected most often in national inspections.
Sources
- Consumer Affairs Agency, “Pesticide residues in food” and FAQ Q1 and Q5 (Japanese)
- Notice Shokuan-hatsu No. 1129001 of November 29, 2005 (notice on enforcement of the positive list system) (Japanese)
- MHLW Public Notice No. 497 (uniform limit of 0.01 ppm) (Japanese)
- Food Safety Commission of Japan, “Evaluation of substances excluded from the positive list system” (updated April 1, 2023) (Japanese)
- MHLW briefing materials (2015) (Japanese)
- Consumer Affairs Agency, “Results of the Survey on Daily Intake of Pesticide Residues etc. in Food, Fiscal 2024” (Japanese)
- MHLW, “Results of Inspections for Pesticide Residues in Food, Fiscal 2024” (Japanese)
Last checked 2026-10-01. Systems and figures change over time. This page is a translation of our Japanese page; if they differ, the Japanese page is the reference.