News Details
Japan Revises Rules on Managing Class I Chemical Impurities Under BAT Framework
On October 6, 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment (MOE) jointly issued a revised notice on the handling of Class I Specified Chemical Substances contained as impurities under the Chemical Substances Control Law (CSCL). The revised notice was published on the same day on the METI Portal.
Previous Framework
The previous framework, established under the 2017 CSCL amendment, allowed exclusion of impurities when managed in accordance with the Best Available Technology (BAT) principle. However, in light of the growing focus on circular economy practices and the use of recycled plastics, the government has reviewed and updated its operational guidance to strengthen control and traceability of chemical impurities.
Key Insights from the Notice
- Impurities and by-products of Class I Specified Chemicals (e.g. hexachlorobenzene (HCB), polychlorinated biphenyls (PCB), and short-chain chlorinated paraffins (SCCP)) must now be managed under BAT to avoid environmental and health risks.
- SDSs must include information on impurity concentrations and management details.
- For recycled plastics, impurity levels must be checked and kept below international control limits, with documentation submitted to MHLW, METI, and MOE.
- Justification reports for by-products such as HCB, PCB, and SCCP are no longer required if impurity levels remain below set limits.
Obligations for Stakeholders
- Manufacturers and importers: Confirm impurity levels, apply BAT, and maintain records.
- Downstream users: Ensure proper communication of impurity-related information via SDSs.
- All operators: Continue efforts to further reduce impurity concentrations below established limits.
Enforcement Dates
The revised notice took effect on 6 October 2025, with immediate applicability to the manufacture, import, and distribution activities involving chemicals and recycled materials containing Class I specified impurities.
We acknowledge that the above information has been compiled from Ministry of Economy, Trade and Industry (METI) Portal - Japan.
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