Japan Proposes Changes to Chemical Substance Exemptions: Public Input Invited

Key Amendments to the Chemical Substances Control Law

The CSCL requires manufacturers and importers of general chemical substances to annually report production and import volumes. However, some substances, deemed to pose minimal risk, are exempt from this requirement. The Ministry of Health, Labour and Welfare, the Ministry of Economy, Trade and Industry, and the Ministry of the Environment have proposed amendments to the exemption list, aiming to include new substances and remove others based on updated scientific evidence​​.

Key updates include:

• Newly Added Substances (Annex 1):
  1. Ethane-1,2-diol-based polymer compounds – Widely used in coatings, these substances lack bioaccumulative properties.
  2. 2-Ethylhexyl acrylate polymers – Common in adhesives, these compounds do not exhibit long-term toxicity to humans or ecosystems.
  3. Cyclohexyl methacrylate derivatives – Known for their application in specialty resins, they are now deemed safe under the latest guidelines​​.
• Substances Proposed for Removal (Annex 2):
  1. 3-Chloro-2-hydroxypropyl methacrylate copolymers – These are flagged due to new evidence of environmental persistence.
  2. Certain perfluorinated acrylates – Previously listed as exempt, they are now linked to bioaccumulation concerns and potential health risks​​.

Why the Amendments Are Necessary

The inclusion and removal of these substances reflect Japan’s commitment to environmental protection and public safety. Newly added compounds are supported by data showing no significant ecological or human health risks. Meanwhile, substances removed from the exemption list are flagged for re-evaluation due to concerns such as toxicity, persistence, or bioaccumulation​​.

Timeline for Public Input

The draft was published on 4 January 2025, and public comments will be accepted until 3 February 2025. Stakeholders are encouraged to submit feedback via the e-Gov platform, email, or postal mail​​.

How to Participate in the Public Comment Process

Opinions can be submitted through the following methods:

• e-Gov platform: Use the official portal to fill in the opinion form.
• Email: Send feedback using the designated template provided by the ministries.
• Postal Mail: Address your comments to the relevant ministry as outlined in the public notice​.

Implications of the Amendments

These updates are expected to streamline the regulatory process, reduce unnecessary burdens on industry players, and ensure continued environmental protection.