Japan Simplifies Registration Requirements for Organic Cyanide Compounds

The Ministry of Health, Labour and Welfare (MHLW) of Japan recently announced that starting from October 2024, a series of revisions to the Regulations for Enforcement of the Poisonous and Deleterious Substances Control Act will be implemented. These changes aim to simplify the registration requirements for organic cyanide compounds and their preparations, enhancing the efficiency and flexibility of chemical management.

Under the current law, enterprises that manufacture or import poisons and deleterious substances for sale or donation must register as manufacturers or importers. They must also obtain a registration change from local governments when adding new varieties. The following key adjustments were made to the registration process for organic cyanide compounds:

• Category Registration: For organic cyanide compounds and their preparations, enterprises no longer need to provide the chemical name in their applications, only category registration is required, and the chemical name column should list organic cyanide compounds.
• Registration Update: When renewing registration, enterprises must submit a list of the types of organic cyanide compounds manufactured or imported since the last update, but only the category types are required, not the specific chemical names.
• Continued Use of Existing Registration: Enterprises that have registered using chemical names can continue to manufacture or import the substance after the new regulations take effect, without needing to re-register or apply for changes.
• No Need for Change in Registration: Enterprises that have registered at least one type of organic cyanide compound can continue to manufacture or import other organic cyanide compounds without needing to change their registration.
• Deleterious Substance Labeling Requirements: When importing organic cyanide compounds classified as deleterious substances, the invoice must indicate the category as organic cyanide compound and its chemical name.
• Registration of Mixtures: When manufacturing or importing mixtures containing organic cyanide compounds, in addition to registering the organic cyanide compound, it is also necessary to register other poisons or deleterious substances according to the original procedures.

The MHLW notes that these revisions will significantly streamline administrative procedures related to organic cyanide compounds while ensuring that necessary safety information continues to be provided. Although the registration process is simplified, chemical names will still be detailed on the product’s containers and packaging, as well as in shipper notifications and information provision, to maintain transparency and safety.