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On 13 December 2017, the Japanese Government announced enforcement dates related to the Chemical Substances Control Law (CSCL), as amended on 7 June 2017. The amendments to the CSCL introduced changes to the control of new chemical substances that are imported or manufactured in small amounts, and to those which are strongly toxic.
According to the announcement, the amendments which address the special exemption system for new chemical substances manufactured/imported in small amounts will come into force on 1 January 2019, while the amendments which strengthen the controls for strongly toxic new chemical substances will come into force on 1 April 2018.
Overview of the amended CSCL
The amendments of 7 June 2017 changed the way to calculate the total amount of new chemical substances manufactured/imported for purposes of the special exemption system. While the previous calculation was based on the actual amount of manufacture/import, the amendments require the calculation to be based on an amount emitted to the environment, using emission factors determined according to the purpose of use.
In addition, to enhance controls of new chemical substances classified as general chemical substances but which are found to be highly toxic as a result of the chemical evaluation, the amendments add the following new measures:
- Notification of the chemical evaluation results by the competent ministries to the company that submitted the notification;
- Publication of the results by the competent ministries to the public;
- Provision of instructions and guidance to companies handing the concerned chemical substances; and
- General duties for companies handling the concerned chemical substances to provide information on the substances to business partners and customers.
Business Impact
As of 1 January 2019, companies planning to manufacture and/or import new chemical substances in small amounts in/to Japan will have to calculate the amounts based on emission to the environment, applying the predetermined emission factor.
If dealing with general chemical substances that are identified as highly toxic, companies will be required to implement measures for proper management after 1 April 2018. This includes obeying instructions and guidance from the ministries and providing chemical information to third parties.
3E Monitor customers may request a copy of the enforcement dates PDF (in Japanese); to do so, please email 3EMonitor@Verisk3E.com. To read more about the 1 June 2017 amendments, please see the 3E Monitor article "Japan Amends New Chemical Substance Controls under Chemical Substances Control Law."
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