Update: On 18 February 2025, Japan officially designated the three chemicals as Class I Specified Chemical Substances, in line with the scheduled notice.
Original Text:
On 5 December 2024, Japan’s Ministry of Economy, Trade and Industry (METI) circulated a draft notice to add methoxychlor, dechlorane plus, UV-328 and their products to the country’s Export Trade Control Order, imposing new restrictions on exporters. METI has published this consultation notice on the e-GOV public comment portal.
New Export Restrictions under Japan’s Export Trade Control Order
Under the provisions of the Export Trade Control Order, exporters are obliged to obtain approval from the METI to ship these chemicals or products containing them. However, the Ministry has not yet published the enforcement date.
Background: METI’s Cabinet Order and Chemical Classifications
On 13 December 2024, the Ministry of Economy, Trade and Industry (METI), the Ministry of Health, Labour and Welfare (MHLW) and the Ministry of Environment (MoE) published an enforcement Cabinet Order designating UV-328, methoxychlor, and dechlorane plus as Class I Specified Chemical Substances.
Class I Specific Chemical Substances List
Compounds classified as Class I Specific Chemical Substances have a high potential for bioaccumulation, persistence, and long-term toxicity to humans or higher trophic-level predator species. The list currently contains 35 compounds.
Exemptions for Specific Applications
According to the draft, dechlorane plus may be used in specific applications, such as defence applications for insulation materials, which are permitted until 26 February 2030.
Comment Period and Enforcement Dates
Stakeholders are invited to comment on this draft notice until 6 January 2025. This designation will come into force on 18 February 2025. From 18 June 2025, Japan will ban the import of products containing dechlorane plus and UV-328 as listed in the table below while the promulgation is expected to occur on 18 December 2025.
Class I Specified Chemical Substance |
Products |
Dechlorane Plus |
Flame retardant chemicals for resins, silicone rubber, lubricating oils, adhesives and tape. Part housings, electrical wiring and cables for electrical and electronic products. |
UV-328 |
Paints and varnishes, lubricating oils, adhesives, tape and sealing fillers and UV absorbers for plastics. |