Japan Updates CSCL Substance List

Japan’s Chemical Substances Control Law (CSCL) continues to evolve, with the list of Newly Announced Chemical Substances now comprising approximately 7,413 substances as of March 31, 2011. These substances are not classified as Class I Specified, Type II or III Monitoring, or Priority Assessment substances, and are thus treated as general chemical substances under Japanese chemical safety regulations.

Classification Summary

Newly Announced Chemical Substances are those that:

• Were notified by manufacturers or importers on or before 31 March 2011.
• Have not been designated under high-risk categories (e.g., Class I Specified Substances).
• Are allowed for general use, subject to annual reporting thresholds.

Regulatory Reporting Requirements

Businesses involved in manufacture or importation of these substances at or above 1 tonne/year are subject to CSCL annual reporting.

Failure to meet these deadlines could result in penalties, enforcement action, or reputational risks.

Authorities Responsible

The management and enforcement of CSCL fall under the oversight of three Japanese government ministries:

• Ministry of Economy, Trade and Industry (METI)
• Ministry of Health, Labour and Welfare (MHLW)
• Ministry of the Environment (MOE)

These bodies work jointly to evaluate chemical risks, ensure compliance, and maintain public safety through detailed substance tracking.

Industry Implications

✔ Compliance Checks

Companies must confirm whether any raw materials, formulations, or imported substances fall within this updated substance list.

✔ Data Accuracy

Maintaining precise production and import volume records is critical for correct reporting.

✔ Monitoring for Updates

Firms should regularly review METI announcements and CSCL updates to track reclassifications, new entries, or changes in reporting thresholds.

Key Takeaways

• Around 7,413 general-use substances are now categorized as Newly Announced Chemical Substances.
• Annual reporting is mandatory when usage exceeds 1 tonne per year.
• Early preparation for June 30 pre-reporting and July 31 final submissions is essential.
• Stay engaged with evolving CSCL regulatory actions and notifications.

References:

i. CSCL Overview – Ministry of Economy, Trade and Industry (METI)
ii. Chemical Substance Notifications and Reporting Requirements (in Japanese)