Reference source : e-GOV Public Comment Portal - Japan
CSCL Hazardous chemicals METI MHLW Public Consultation Ministry of Environment MOE Chemical Reporting Requirements Japan Law Amended
On 18 March 2026, Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI) and Ministry of the Environment (MoE) jointly published a draft on hazard reporting of existing chemicals under the Chemical Substances Control Law (CSCL). The draft was published on Japan’s e-GOV Public Comment Portal.
Background
Under Article 41 of the CSCL, manufacturers and importers are required to report to the authorities whenever new hazard information on chemical substances, including data on persistence, bioaccumulation, and toxicity becomes available. This obligation ensures that the government is kept informed of any potential risks associated with chemicals already in circulation, enabling it to take appropriate regulatory action to protect human health and the environment.
Key Insights from the Amendment
The draft indicates the following key changes:
The amendments clarify that monitoring chemical substances do not require persistence and bioaccumulation data to be reported, as these properties are already known.
For Class II Specified Chemical Substances, the reporting requirements are clarified, including the submission of persistence-related data.
Obligations for Stakeholders
Manufacturers and importers must report new hazard information and adapt to electronic submissions via the e-Gov platform. They should follow the updated reporting formats and ensure that their internal compliance systems are aligned with the revised requirements.
Comment Period and Enforcement Dates
Interested stakeholders may submit comments until 16 April 2026. The final order is expected to be promulgated following the consultation period with implementation planned for May 2026.
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