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Japan Revises CSCL Enforcement Order

  •   5 Mar 2018
  •    Matt Lyu
  •    2363
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    The revision of Japanese Chemical Substance Control Law (CSCL) began in early 2017. The amendments were voted and passed by the Japanese government in March 2017. After that, the Ministry of Economy, Trade and Industry (METI) and the Ministry of Environment (MOE) set the enforcement dates of the amendments in Dec 2017. The draft determination standards of the specified new chemicals were carried out by METI in Feb 2018. 

    On Feb 21st, 2018, METI issued a government gazette and stipulated the amendments to the Cabinet Order for Enforcement of CSCL which is a supportive regulation to CSCL. The main amendments include 5 parts and will take effect from different dates:

    1. Reiterated that the upper limit for small volume substance notification is 1 ton/year (release amount) and 10 ton/year (release amount) for low volume notification. It should be noted that the threshold here is the calculated release amount, instead of the import and manufacture amount. The definition and calculation method of release amount can be seen here. However, according to the seminars held by METI, the maximum import or manufacture amounts of small volume notification and low volume notification that a single enterprise can apply for are still 1 ton and 10 ton, no matter how small the release amounts are.

    The detailed release factors are not published in the amendments because they are still under internal discussion. The final results of the release factors are expected to appear in the coming implementation rules of CSCL. This amendment will take effect from Jan 1st, 2019.

    1. Two substances were added as Class I Specified Substance. This amendment will take effect from Apr 1st, 2018.
    2. 15 products were added as the products prohibited from import if the Class I Specified Substances were used. This amendment will take effect from Oct 1st, 2018.
    3. 3 use conditions that the Class I Specified Substances are allowed to be used were deleted. This amendment will take effect from Apr 1st, 2018.
    4. As a result of the No.4, the requirements of the technical standards when using Class I Specified Substances were deleted, too. This amendment will take effect from Apr 1st, 2018.

    Some other tasks mentioned at METI seminars that the authorities will try to carry out in the future include:

    • Development of the electronic notification;
    • More windows for small and low volume notification;
    • Separated notifications for different uses;
    • Proof requirements for the use of chemicals;
    • Submission of molecular structure of the substance;
    • Acceptance of the 301F, simplified 201C, PFS procedures, etc. that are implemented abroad.

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