News Details
Japan: METI amends provisions under Export Trade Control Order
On 1 September
2025, Japan’s Ministry of Economy, Trade and Industry (METI) released draft to
amend provisions of Export Approval for Chemical Substances under Export
Trade Control Order. Consultation notice was published on the Japan’s e-GOV
Public Comment Portal. The Japanese Export
Trade Control Order is a key regulation under the Foreign Exchange and Foreign Trade Act.
Export
Trade Control Order
Under the Japanese Export Trade Control Order
(Cabinet Order No. 378 of 1949), the export of certain chemical substances
is strictly regulated through an export approval system administered
by the Ministry of Economy, Trade and Industry (METI). This framework aligns
Japan with international obligations under the Rotterdam and Stockholm
Conventions and the Chemical Substances Control Law (CSCL).
Exporters must obtain prior authorization when shipping hazardous chemicals
such as pesticides, persistent organic pollutants (POPs), mercury compounds,
asbestos, and PFAS, including mixtures, formulations, and even finished
products containing these substances. The system ensures that Japan fulfills
its role in safeguarding human health, the environment, and international
security by preventing the uncontrolled transfer of dangerous chemicals.
Provisions
drafted under Consultation Notice
Revised
provisions are summarised in below table:
|
Provision |
Before
(Current Rule) |
After
(Amendment) |
|
Scope
of chemicals |
Limited list under Rotterdam Convention Annex III |
Expanded to include mixtures and formulations
containing listed chemicals |
|
Pesticides |
Some pesticides controlled, but not all
formulations specified |
Added controls for: • Carbosulfan (CAS 55285-14-8) • Powder formulations containing Benomyl,
Carbofuran, and Thiram (with thresholds) • Fenthion, Methyl Parathion, Phosphamidon
(restricted unless very specific high-concentration forms) |
|
POP
substances |
Partial coverage (older list) |
Expanded list including DDT, Aldrin, Dieldrin,
Endrin, Chlordane, Hexachlorobenzene, Mirex, Toxaphene, PCBs, PBBs, PCTs,
etc. |
|
PFAS |
Only PFOS explicitly listed |
Now includes PFOS, PFOA, PFHxS, and related
salts/precursors |
|
Other
hazardous chemicals |
Asbestos, mercury compounds covered in a limited
sense |
Broader coverage (all asbestos types, all mercury
compound categories, brominated flame retardants, chlorinated paraffins,
etc.) |
|
Articles
containing restricted chemicals |
Not clearly regulated |
Explicitly
included (e.g.,
textiles with PFAS, paints, lubricants, semiconductors, foams, fire
extinguishers) |
Comment Period and Enforcement Dates
Stakeholders are informed to submit comment on this draft provisions by 2 October 2025. While METI has not published the enforcement dates yet.
We acknowledge that the above information has been compiled from e-GOV Public Comment Portal - Japan.
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