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Japan solicits consultation to amend guidelines under CSCL

2025-08-21 Reference source : Ministry of Economy, Trade and Industry (METI) Portal - Japan

Consultation CSCL METI MHLW update Ministry of Environment MOE Japan


On 20 August 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI) and Ministry of the Environment (MoE) jointly released the draft amendments to guidelines under Chemical Substances Control Law (CSCL). Ministry released the draft notification on the Japan’s e-GOV Public Comment Portal. The ministries plan to update these operational guidelines in light of the 2025 assessment of the 2017 CSCL amendment and plans for chemical substance management in the future. The March 29, 2019 notification on managing by-product Class I Specified Substances will also be revised.   

Key Amendments from draft notification

Article 1 – Impurities containing Class I Specified Substances:

  • Previously, rules only applied when Class I Specified Substances were present as by-products.
  • Now, rules will also apply when they are present as impurities (broader definition, including by-products).

Article 2 – Structural Changes and Clarifications:

  1. Restructuring:
    • Establish a new section "1. Common Provisions" to consolidate rules that apply across the entire guideline.
  2. Clarifications:
    • Clarify treatment of anhydrous vs. hydrated substances.
    • Clarify definitions of terms for organic polymers.
  3. Existing vs. New Substances:
    • Some substances previously excluded from being treated as "new" will now be explicitly treated as existing chemical substances, with reference to specific provisions in the law (Article 2, paragraphs 4, 5, 7).

Article 3 – Existing Chemicals:

  • Revision of the definition of "existing chemical substances" with necessary updates.

Comment Period and Enforcement Dates 

Stakeholders are invited to submit comment on the draft amendment by 19 September 2025. While Japan will adopt this draft notification in late September 2025. Enforcement will occur in phased manner, implementation dates are tabulated below: 

Particulars 

Enforcement Dates 

Article 1 

1 October 2025  

Article 2

1 April 2026 

Article 3

1 April 2027



We acknowledge that the above information has been compiled from Ministry of Economy, Trade and Industry (METI) Portal - Japan.

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