Japan: METI Amends Notifications Provisions for Chemicals under CSCL

On 5 August 2025, Japan’s Ministry of Economy, Trade and Industry (METI) published draft amendments to notification provisions for the manufacture or import of chemicals under Chemical Substances Control Law (CSCL). The draft was released on Japan’s e-GOV Public Comment Portal. The changes apply to: 

• General chemical substances
• Priority assessment substances
• Monitoring chemical substances
• Class II specified chemical substances  

Key Insights from the Draft

METI has proposed the following revisions in the draft: 

I. Amendment to the Ministerial Ordinance

1. Cleanup of Regulations (Articles 18 & 19)

• Article 18 and 19 (previously marked for deletion) will now be formally removed.

2. Changes to Electronic Notification Requirements (Articles 20–21)

• In addition to electronic signatures, user-set passcodes (such as G Biz ID) become acceptable authentication methods.
• This applies to notifications for:
  • General chemical substances (Article 9-2)
  • Priority assessment substances (Article 9-3)
  • Monitoring chemical substances (Article 10)
  • Class II specified chemical substances (Article 15)

The notifier code requirement will be abolished and replaced with the new passcode system. As a result, Article 21 will be repealed.

3. Revision of Article 19

A new Article 19 will clarify name/identity declaration requirements in line with Article 6(4) of the Act on Advancement of Utilizing Information and Communication Technology in Administrative Procedures (Law No. 151 of 2002).

4. Other Related and Formatting Amendments:

Additional revisions will be made to: Articles 5-2, 9-2, 9-3(2), 10(2), 15(2), and Article 22 (renumbered as Article 20),as well as to the Supplementary Provisions on transitional measures.

II. Amendment to METI Notification Related to Technical Standards

The notification specifying the technical standards for computers and electronic certificates under Articles 20 and 20-2 will be updated to reflect the regulatory changes mentioned above .

Comment Period and Enforcement Dates 

Stakeholders are invited to comment on the draft by 3 September 2025. METI plans to publish the final draft in October 2025, while enforcement is scheduled to begin on 1 April 2026.