Japan has introduced new handling rules under the Chemical Substances Control Law (CSCL) for cases where Class I Specified Chemical Substances are unintentionally present as trace impurities in chemicals or recycled materials.
Key Highlights:
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Class I Specified Chemical Substances are generally prohibited to manufacture, import, or use due to their hazardous nature.
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If these substances occur unintentionally as impurities during production, companies must apply the BAT (Best Available Technology) principle to reduce concentrations to the lowest practical level.
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If impurity levels are reduced to a level with no recognized environmental or health risk, they may not be treated as regulated Class I substances.
Company Obligations:
Businesses that manufacture or import such chemicals must:
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Set a BAT-based voluntary management upper limit
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Submit reduction measures and justification to MHLW, METI, and MOE in advance
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Continuously monitor impurity levels
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Keep reducing concentrations where possible
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Report management status if requested
Threshold Values for Certain Chemicals:
For some specified substances, Japan has introduced fixed threshold values. If managed within these limits and reported properly, periodic reporting is not required.
Recycled Plastics Included:
The new rules also cover plastic recyclates using post-consumer plastic, where trace legacy hazardous substances may remain.
Why It Matters:
These changes impact:
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Chemical manufacturers
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Importers exporting to Japan
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Plastic recyclers
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Supply chains handling industrial chemicals
Handling of Plastic Recyclates
To support the circular economy, Japan has clarified requirements for the manufacture or import of plastic recyclates made partly from post-consumer plastic waste. Where Class I Specified Chemical Substances may be present in trace amounts and international management limits are available, businesses must submit prescribed documentation in advance to the three ministries, demonstrating that the substances will be managed in line with the BAT (Best Available Technology) principle.
