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 amendment to the Export Trade Control Order, revising provisions related to export approval for chemical substances. The consultation notice was published on Japan’s e-GOV Public Comment Portal.
The Export Trade Control Order (Cabinet Order No. 378 of 1949) is a key regulation under the Foreign Exchange and Foreign Trade Act, establishing the legal basis for Japan’s export control system. The framework requires prior authorization for exports of hazardous chemicals and substances that could pose environmental or health risks, in line with Japan’s commitments under the Rotterdam Convention, the Stockholm Convention, and the Chemical Substances Control Law (CSCL).
Key Provisons in the Drafted Amendment
The revised
provisions are summarised in the table below:
|
Provision |
Before
(Current Rule) |
After
(Amendment) |
|
Scope
of chemicals |
Limited to chemicals listed 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 except for 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 |
Limited coverage of asbestos and mercury compounds |
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) |
Consultation and Next Steps
Stakeholders are invited to submit comment by 2 October 2025. The enforcement date of the ameded Order has not yet been announced.
We acknowledge that the above information has been compiled from e-GOV Public Comment Portal - Japan.
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