Japan Updates CSCL Rules

Japan’s Ministry of Economy, Trade and Industry (METI), together with MHLW and MOE, has issued a major update to the Chemical Substances Control Law (CSCL). The revision introduces Best Available Technology (BAT)-based management for cases where Class I Specified Chemical Substances are present only as impurities or by-products—not as intentionally added chemicals.

The update aligns with Japan’s broader shift toward circular-economy chemical regulation, improving oversight while reducing unnecessary regulatory burden.

Changes in the CSCL Revision

1. BAT Management for Class I Impurities

Class I chemicals present solely as impurities/by-products may be exempt from full Class I classification if managed under BAT.

Companies must monitor impurity concentrations, control releases, and maintain traceability records.

2. Strengthened SDS Requirements

When distributing or shipping materials containing such impurities, companies must disclose impurity levels, BAT measures, and risk-management practices in Safety Data Sheets (SDS).

3. Special Rules for Recycled Materials

Recycled plastics and waste-derived materials must undergo impurity testing, BAT-based control, and documentation before manufacturing or import.

For certain globally regulated substances, if impurity levels stay below international thresholds, stricter self-management reporting may be eased.

Action plans for Companies:

• Review production processes and supply-chain impurity data.
• Apply BAT for impurity control and document risk-management measures.
• Update SDS to reflect impurity content and compliance actions.
• Conduct impurity testing for recycled or reused feedstock before market entry.

Importance of the Revision:

The new policy reduces compliance burdens for industries—especially recycling and plastics—while maintaining strong environmental protection.

It offers a more practical framework for managing impurities and strengthens traceability, SDS transparency, and lifecycle chemical oversight—key pillars of Japan's evolving chemical regulatory landscape.

Reference: Japan CSCL