The Ministry of Economy, Trade and Industry (METI) of Japan, under the Chemical Substances Control Law (CSCL), has recently announced revisions to the Priority Assessment Chemical Substances (PACS) List and changes to the production and import quantity reporting requirements. These updates include the removal of seven substances from the PACS List and the addition of three new substances, along with revised reporting obligations.
Changes to the PACS List
Substances Removed from Priority Assessment Designation
Effective March 31, 2025:
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N,N-Dimethylformamide
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1,3-Diisocyanatomethylbenzene
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Potassium 2-ethylhexanoate
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Ethyl hydrogen sulfate
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4,4′-Diamino-3,3′-dichlorodiphenylmethane (also known as 4,4′-Methylenebis(2-chloroaniline))
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Bicyclo[2.2.1]heptane-2,5(2,6)-diyl=dicyanide mixture
Effective April 1, 2025:
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α-(Styrenyl)-ω-hydroxypoly(oxyethylene) (also known as Poly(oxyethylene)=styryl ether)
Substances Newly Designated as PACS (Effective April 1, 2025):
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Copper(I) thiocyanate
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N-Decyl-N-ethyl-N-methyl-1-decanium salt
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α-Hydroxy-ω-[(9Z)-octadec-9-enoyloxy]poly(oxyethylene-1,2-diyl) (n = 1 or more repeating units)
Reporting Requirements
For Substances Removed as of March 31, 2025:
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Report actual production and import quantities for FY2024 as General Chemical Substances.
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If not reclassified, continue reporting under the same category from FY2026 onward.
For Substance Removed as of April 1, 2025:
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Report actual FY2024 quantities as a Priority Assessment Chemical Substance.
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If classified as a Class II Specified Chemical Substance for FY2025, report estimated quantities for that year.
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From FY2026 onward, report both estimated and actual quantities under the Class II category.
For Substances Newly Added as of April 1, 2025:
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Report FY2024 quantities as General Chemical Substances for FY2025.
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From FY2026 onward, report as Priority Assessment Chemical Substances, including actual production and import data.
For PACS Designated as of April 1, 2024 (Serial Nos. 274–285):
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Begin reporting as Priority Assessment Chemical Substances from FY2025 onward, following the standard criteria.
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