Japan Regulatory News

On 30 June 2025, Japan’s Ministry of Economy, Trade and Industry (METI) published its Implementation Report on the Chemical Substances Control Law (CSCL)  for Fiscal Year 2024 (FY2024) on its porta...

On 30 June 2025, Japan’s Ministry of Economy, Trade and Industry (METI) published its Implementation Report on the Chemical Substances Control Law (CSCL)  for Fiscal Year 2024 (FY2024) on its portal. METI releases this report annually to provide an update on the current status. The previous report, covering FY 2023, was released by METI on 21 June 2024. 

Key Insights from the Implementation Report 

1. Overview of the CSCL 

The CSCL aims to prevent environmental pollution caused by chemical substances that may harm human health or ecosystems. It mandates: 

• Pre-market evaluation of new chemical substances. 

• Post-market control through reporting on production/import volumes and toxicity information. 

• Regulatory designation of substances based on characteristics such as persistence, bioaccumulation, and toxicity. 

Substance categories include: 

• Class I Specified Chemical Substances: Most strictly regulated. 

• Class II Specified Chemical Substances: Pose long-term risks. 

• Monitored Chemical Substances: Persistent and bioaccumulative but with unknown toxicity. 

• Priority Assessment Chemical Substances and General Substances: Subject to reporting and potential future regulation. 

2. Notifications and Preliminary Evaluations (FY2024) 

• 319 new chemical notifications were assessed, with most classified as low-risk. 

• Breakdown: 34 substances showed concern for both human and environmental health. 115 were classified as low risk. 

• 1,825 low-volume (≤10 tons/year) new chemical confirmations were submitted.  

• Over 37,000 small-volume (≤1 ton/year) notifications were submitted. 

• Main uses include: Intermediates, electronic materials, paints/coatings, cleaning agents, adhesives and fragrances. 

3. Post-Market Risk Management 

• Annual reporting is required for general and priority chemicals produced or imported at ≥1 ton/year. 

• Risk evaluations are conducted using usage volume, hazard data, and monitoring results. 

• 48 substances have undergone Tier II (advanced) evaluations to date. 

• Based on these assessments, some substances may be designated as Class II Specified Chemicals. 

4. Regulatory Measures Based on Chemical Characteristics 

• Substances such as PFHxS, chlorpyrifos, MCCP, and LC-PFCA are under discussion for designation as Class I Specified Chemicals, in line with international obligations (e.g., Stockholm Convention). 

• The public consultation and regulatory updates are scheduled through FY2025 and early FY2026. 

5. Monitoring and Control Data 

• Production and import data for Monitored Chemicals and Class II Specified Chemicals are tracked annually. 

• Notable reductions have been observed for high-risk substances such as trichloroethylene and tetrachloroethylene. 

• Reported hazards from companies include biodegradability, bioaccumulation, and human/ecotoxicity findings (over 200 reports in FY2024). 

The full report can be found here. 

Update: On 30 June 2025, Japan’s Consumer Affairs Agency (CAA) released the promulgated order for new PFOS and PFOA standards for mineral water on the e-GOV Public Comment Portal.      Ori...

Update: On 30 June 2025, Japan’s Consumer Affairs Agency (CAA) released the promulgated order for new PFOS and PFOA standards for mineral water on the e-GOV Public Comment Portal.   

Original Text: 

On 26 February 2025, Japan’s Consumer Affairs Agency (CAA) notified the World Trade Organization (WTO) of a proposed revision to water quality standards under the Food Sanitation Act. This revision aims to establish specifications for sterilized or filter sterilized mineral water. At the same time, the CAA published this notice on Japan’s e-GOV Public Comment Portal.  

Background 

According to Article 12 of the Food Sanitation Act 1947, the Prime Minister may allow the sale of specific food additives. However, the Health and Welfare Public Notice No. 370 of 1959 prohibits the sale of food additives unless they comply with the regulations, as set out in Article 13 of the Act.  

The Food Safety Commission of Japan (FSCJ) has reviewed specifications and standards for mineral water and assessing the health effects of synthetic organofluorine chemical compounds, particularly per- and polyfluoroalkyl substances (PFAS), in food. As a result, Japan will establish water quality standards for perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) in sterilized or filter sterilized mineral waters under the Water Supply Act. 

New Standards for Mineral Water  

The following new standards for PFOS and PFAS in mineral water will be established: 

Comment Period and Enforcement Dates 

The 60-day comment period will end on 27 April 2025. The newly established standards are expected to be enforced from 1 April 2026.  

On 27 June 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) announced the addition of 119 new chemicals to the New Chemicals List under the Industrial Safety and Health Act (ISHA). This u...

On 27 June 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) announced the addition of 119 new chemicals to the New Chemicals List under the Industrial Safety and Health Act (ISHA). This update was announced through an official ISHA Notice published on the same day.   

The new entries, along with their ISHA official gazette serial numbers, chemical names, and structural formulas are available on MHLW's Workplace Safety Portal here.  

Previous addition: 157 New Chemical Substances in March 2025   

This revision follows the addition of 157 new chemicals to the list, as reported in an ISHA notification published on 27 March 2025, via the MHLW Workplace Safety Portal. The update can be found here.  

  
Obligations for Stakeholders   

Currently, the list of chemicals known as the Existing and New Chemical Substances (ENCS) list includes 72,720 entries. According to the Industrial Safety and Health Act, Japanese enterprises that produce or import such compounds must notify the MHLW. In order to safeguard industrial workers' health, the notification must contain the name of the new chemical compound and details of its risk assessment.   

Japan’s Positive List (PL) for food contact materials (FCMs) entered into force on 1 June 2025. On the same day, the Consumer Affairs Agency (CAA) published a manual introducing the positive list on...

Japan’s Positive List (PL) for food contact materials (FCMs) entered into force on 1 June 2025. On the same day, the Consumer Affairs Agency (CAA) published a manual introducing the positive list on its official portal. The PL system regulates synthetic resins used in food-contact utensils and packaging under the Food Sanitation Act. Only materials listed in the official PL may be used, unless they meet certain exemption criteria, such as migration into food below 0.01 ppm or use in non-contact layers that do not affect food safety.

Key Insights from the Manual

1. Legal Basis:

• Article 16: Bans harmful substances in utensils, containers, and packaging (UCP).

• Article 18: Enables the establishment of safety standards and manufacturing criteria.

2. Structure of Standards:

• General Standards: Ban certain harmful substances such as lead and certain dyes.

• Material-specific and Use-specific Standards: Apply to categories such as glass, rubber, and heat-processed materials (e.g. retort pouches).

3. Annex I (Positive List):

• Table 1: Lists 21 categories of approved base polymers.

• Table 2: Includes approximately 840 approved additives, each with usage limits by material class.

4. Scope of Application:

• Covers all synthetic resin layers in UCPs.

• Excludes non-resin materials, surface coatings, and unintended by-products.

5. Procedures for Adding New Substances:

• Inclusion via PL amendment, safety review, or monomer notification update - depending on intended use and risk.

6. Transition Period:

• A 5-year grace period until 1 June 2030.

• Products sold or made before enforcement are considered compliant during this period.

Stakeholder Obligations

• Manufacturers and importers of raw materials and UCPs must provide evidence of PLcompliance.

• Users and distributors must verify and communicate compliance.

• Disclosure of individual substances is not mandatory; documentation such as specification sheets or certificates is sufficient.

The PL system is designed to enhance food safety by systematically controlling materials used in food-contact applications.

Update: On 6 June 2025, Japan’s Ministry of Health, Labour, and Welfare (MHLW) published the revised list of 155 chemicals which require labelling and safety data sheets (SDS) on the ASEAN-Japan Che...

Update: On 6 June 2025, Japan’s Ministry of Health, Labour, and Welfare (MHLW) published the revised list of 155 chemicals which require labelling and safety data sheets (SDS) on the ASEAN-Japan Chemical Safety Database portal. The updated list was also  made available on the nation's National Institute of Technology and Evaluation-Chemical Risk Information Platform (NITE-CHRIP) website.  Enforcement will begin on 1 April 2027. 

Original Text: 

On 16 May 2025, Japan’s Ministry of Health, Labour, and Welfare (MHLW) published the revised list of compounds and mixtures that required labelling and safety data sheets (SDS). The list is available on the country’s Workplace Safety Portal, managed by the Ministry. According to the Industrial Safety and Health Act (ISHA), the Globally Harmonized System (GHS) for labelling must be followed.  

List of Labelling & SDS Delivery 

According to Article 57 and 57-2 of the ISHA, it is mandatory to provide a label and SDS for the listed chemicals to safeguard workers’ health and the environment. A total of 2316 chemicals are now listed, with requirements coming into effect in phases from April 2025 and April 2026. 

Previous Update in March 2025 

In March 2025, the MHLW released a list of 7 chemicals subject to labelling and SDS delivery. 

Insights from the Amended List 

From the revised list, the following must have label and SDSs: 

• 1530 chemicals applicable from 1 April 2025 

• 779 chemicals applicable from 1 April 2026 

Obligations for Stakeholders 

Manufacturers, importers, suppliers, and employers are subject to labelling and Safety Data Sheet (SDS) delivery obligations under Japan's Industrial Safety and Health Act (ISHA).  

On 6 June 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) published a list of 50 carcinogenic chemicals on the ASEAN-Japan Chemical Safety Database portal. The update was also released o...

On 6 June 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) published a list of 50 carcinogenic chemicals on the ASEAN-Japan Chemical Safety Database portal. The update was also released on the country’s National Institute of Technology and Evaluation - Chemical Risk Information Platform (NITE-CHRIP) portal.  

Background 

In Japan, carcinogenic substances are subject to strict obligations under the Industrial Safety and Health Act (ISHA), which requires records to be kept for up to 30-years. 

Previous update in December 2022 

Earlier, in December 2022, the MHLW classified 200 chemicals as carcinogenic and started enforcement in a phased manner starting from April 2023. More details can be found here.  

Obligations for Stakeholders 

From 1 April 2027, the following will be mandatory for stakeholders: 

• Mandatory GHS-compliant labelling and provision of Safety Data Sheets (SDS). 

• Risk assessment before use, implementation of exposure control measures, and health monitoring for workers.  

• Employers must conduct regular medical examinations, particularly for substances classified as Group 1 or 2A carcinogens, maintain detailed exposure and health records, and notify authorities when required.  

• Additional regulations, such as the Chemical Substances Control Law (CSCL) and PRTR Law, also apply to environmental reporting and emissions control. 

On 29 May 2025, Japan’s Ministry of Environment (MoE), launched a public consultation to collect toxicity data on chemical substances regulated under the Chemical Substances Control Law (CSCL). The ...

On 29 May 2025, Japan’s Ministry of Environment (MoE), launched a public consultation to collect toxicity data on chemical substances regulated under the Chemical Substances Control Law (CSCL). The MoE has requested this data to further accelerate and optimize the risk assessment of Priority Assessment Chemicals (PACs) and general chemicals under the CSCL.  

Background 

The MoE periodically reviews the toxicity information of chemicals to help protect human health and the environment. It also revises the classification accordingly and makes this information publicly available through the Ministry’s portal. 

Chemicals covered under the consultation  

The consultation covers two classes of chemicals under the CSCL: 

• PACs: 53 entries  

• General Chemicals: 81 entries 

Information to be submitted 

The MoE requests companies to submit toxicity information for the following endpoints: 

• Acute or chronic toxicity to algae 

• Acute or chronic toxicity to crustaceans 

• Acute or chronic toxicity to fish 

The Ministry has also shared guidance on assessment methods and the preparation of documents for submission, which is available in detail through the consultation notice. 

Consultation Period 

Stakeholders are invited to submit the required toxicity information to the MoE by 31 July 2025.