Japan’s Ministry of the Environment has issued a formal request to industry stakeholders to submit ecotoxicity data on 134 chemical substances by 31 July 2025. This initiative, under the Chemical Substances Control Law (CSCL), aims to accelerate and improve the accuracy of risk assessments for both general and priority assessment substances. The policy has direct implications for manufacturers, importers, and businesses across the supply chain handling chemical products in Japan.
Ecotoxicity data request under CSCL explained
The Ministry’s announcement includes a list of 70 general chemical substances and 64 priority assessment substances identified as lacking sufficient hazard data, especially for aquatic toxicity. These substances range from common industrial chemicals and polymers to more specialised compounds, many of which are widely used in manufacturing, packaging, coatings, and formulations.
Without the provision of new data, the government will apply default hazard classifications (e.g. Class 1 for ecotoxicity), which could result in more conservative predicted no-effect concentrations (PNECs). This defaulting mechanism may lead to stricter regulatory limits and potentially trigger risk management measures.
Impact on manufacturers, importers, and the wider supply chain
The Ministry urges businesses who manufacture or import the listed substances and possess credible ecotoxicity data—such as algae, crustacean, or fish toxicity—to submit reports by the deadline. Even companies not currently handling these chemicals are encouraged to participate if they have relevant data from prior use or testing.
Failure to respond may result in substances being inaccurately categorised as higher risk, which could affect marketability, authorisations, and environmental compliance requirements. This request also reflects Japan’s broader shift towards data-driven, transparent chemical safety policies under the CSCL.
Guidance on submission and regulatory documentation
Submissions must follow reliability evaluation criteria outlined in Japan’s CSCL risk assessment framework. Relevant documents include:
- The 2011 guideline on reliability of ecotoxicity data
- The 2014 technical guidance on ecological hazard evaluation under CSCL
- The Ministry's online portal for submitting hazard information
Submissions must include a formal hazard information report, supporting evidence, and final test reports. Where applicable, reports must align with Article 41 of the CSCL.
