Japan's New Chemical Reporting Requirements
Reports Due in June 2011
On April 1, 2011, a new reporting
requirement for chemicals came into effect in Japan. This new requirement
originated in the 2009 amendment to Japan's chemical control law and requires
that companies submit an annual report on chemical substances manufactured or
imported into Japan. The first round of reports must be submitted by June 30,
2011, to the Ministry of Economy, Trade and Industry (METI).
New Reporting Requirement in Japan
The primary chemical control law in
Japan is the Law Concerning the Examination and Regulation of Manufacture,
etc., of Chemical Substances (Law No. 117 of October 16, 1973). The law was
most recently amended in 2009 to add, among other things, an annual reporting
The new scheme imposes a reporting
obligation on companies manufacturing or importing more than one metric ton of
a "general chemical substance" or a substance designated as a
"priority assessment chemical substance" (PACS). METI has issued a
list of chemical substances designated as PACSs as of April 1, 2011, available
When METI receives a report, or
notification, it will conduct a screening evaluation designed to identify any
additional chemicals that should be classified as PACSs. Any substance selected
as a PACS will undergo a risk assessment by METI, and the Ministry may require
its manufacturer or importer to submit information on the substance's hazardous
properties. Depending on the outcome of the assessment, METI may restrict the
manufacture or use of the substance.
Notification Contents and Format
The notification must state the
identity of the chemical substance and, if known, its Chemical Abstract
Services Registry Number (CASRN). The notification must include the amount of
the substance that was manufactured or imported during the previous calendar
year, rounded to one significant digit. For example, 12,499 metric tons should
be rounded to 10,000 metric tons, and 1,894 metric tons should be rounded to
2,000. Finally, the notification should specify the use of the substance,
selected from one of the use categories provided by METI. On February 8, 2011,
METI released an updated list of use categories, which is available at http://www.meti.go.jp/policy/chemical_management/english/files/use%20category.pdf.
For general chemical substances,
companies must use notification Form 11. For PACSs, companies must use Form 12.
Examples of these forms are available at http://www.meti.go.jp/policy/chemical_management/english/files/CSCL-setsumei-H22-12-jizen-12eng.pdf
(pages 7-8 and 11-13, respectively). The notification form may be submitted by
paper, electronically, or by CD. METI is developing software that will enable
companies to generate notification documents electronically, and it plans to
make this software available free of charge.
The notification must be submitted
annually to METI between April 1 and June 30.
Exemptions from Reporting
As explained above, the reporting
requirement applies to chemical substances that are manufactured or imported in
quantities of at least one metric ton per year. Certain substances determined
not to be persistent or bioaccumulative are only subject to the reporting
requirement if manufactured or imported in quantities of at least 10 metric
tons. Note that "existing" chemical substances are subject to the
The law does exempt the following
types of substances from reporting:
For more information, please see
guidance documents issued by METI, at http://www.meti.go.jp/policy/chemical_management/english/cscl.html.
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