On 12 February 2025, Japan’s Ministry of Environment (MoE), together with the Ministry of Health, Labour and Welfare (MHLW) and the Ministry of Economy, Trade and Industry (METI) released a joint draft notice on its portal to amend the Priority Assessment Chemical Substances (PACS) list. This update will add 3 newly designated PACS and remove 7 PACS from the list. Following assessment of the chemicals, the three ministries have opened a public consultation on the same. In Japan, the Chemical Substances Control Law (CSCL) governs Priority Assessment Chemical Substances (PACS).
Background on PACS
PACS are chemicals whose long-term effects on humans or the plants and animals that live in human habitats are not well understood. Therefore, in order to ensure compliance with METI laws and to encourage safety and responsibility in handling of chemicals, companies that manufacture or import these chemicals in quantities greater than 1 Tonne Per Annum (TPA) are required to file annual reports in order to protect living beings.
Key Insights from the draft notice
The draft notice lists the following chemicals that are proposed for addition to the PACS list because of their potential for causing long-term harm to humans or to plants and animals in the human environment is not fully understood:
List of Newly Designated PACS
Registration No. |
Name of Chemical Substance |
CAS No. |
MITI No. |
Enforcement Date |
286 |
Copper(I) thiocyanate |
1111-67-7 |
1-129 |
1 April 2025 |
287 |
N-Decyl-N-ethyl-N-methyldecan-1-aminium salt |
- |
2-184, 9-1971 |
|
288 |
α-Hydro-ω-{[(9Z)-octadeca-9-enoyl]oxy}poly(oxyethane-1,2-diyl) (with a repeating unit integer of 1 or more) |
68154-27-8, 68154-31-4 |
7-88, 7-319, 7-1392 |
The draft notice also lists the following chemicals whose PACS designation will be revoked due to:
Manufactured/imported volumes of less than 10 TPA reported for 3 consecutive years.
Indicated released volumes of less than 1 TPA to the environment.
Indication that they no longer pose a risk to living organisms.
List of PACS to be delisted from the PACS list
Registration No. |
Name of Chemical Substance |
CAS No. |
MITI No. |
Enforcement Date |
27 |
N,N-Dimethylformamide |
68-12-2 |
2-680 |
31 March 2025 |
86 |
α-(Nonylphenyl)-ω-hydroxy poly(oxyethylene) (Also known as Poly(oxyethylene) nonylphenyl ether) |
26027-38-3 |
7-172 |
1 April 2025 |
129 |
1,3-Diisocyanato(methyl)benzene |
14219-05-7 |
3-2214 |
31 March 2025 |
230 |
Potassium 2-ethylhexanoate |
3164-85-0 |
2-611 |
|
244 |
Ethyl hydrogen sulfate |
540-82-9 |
2-3231 |
|
255 |
4,4'-Diamino-3,3'-dichlorodiphenylmethane (also known as 4,4'-Methylenebis(2-chloroaniline)) |
101-14-4 |
4-95, 4-96, 4-275 |
|
256 |
Mixture of bicyclo[2.2.1]heptane-2,5(or 2,6)-diyl dicyanide |
132112-66-4, 132112-67-5 |
4-1715 |
Comment Period
Stakeholders are invited to comment on this joint draft notice till 13 March 2025. After receiving the comments, the three ministries will publicly announce further updates.