Tuesday, December 30, 2014

Japan CSCL: Chemical Substances Control Law

The Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (hereinafter the "Chemical Substances Control Law" or "Japan CSCL") was firstly enacted in 1973 to prevent environmental pollution by chemical substances that pose a risk to human health or the environment. That latest amendment was made in 2009. Full implementation of amended CSCL started from 1 April 2011. 

Main Requirements of Japan CSCL 

Japan CSCL controls both new and existing substances. For new substances, a strict pre-manufacture evaluation system is implemented. For existing substances, manufacturers or importers are required to report their quantity and uses annually if the volume of manufacture (M) or importation (I) exceeds certain amount. CSCL also designates substances subject to priority risk assessment and prohibits some substances from M/I. 


New Substance Notification under Japan CSCL

A person who intends to manufacture or import a new chemical substance shall notify it to three ministries at least three months prior to the manufacture or importation. The three ministries are the Ministry of Economy, Trade and Industry (METI), the Ministry of Labor and Welfare (MHLW), and the Ministry of the Environment (MOE).

A new substance is defined as a chemical substance other than the following substances:
    • A substance that is on the list of existing and new chemical substances (ENCS);
    • Monitoring chemical substances;
    • Priority assessment chemical substances;
    • Class I or II specified chemical substance;

Japan ENCS consists of two parts:
    • Existing chemical substances placed on Japanese market before 16 Oct 1973 (approximately 20,600 substances);
    • New chemical substances that have been notified under the CSCL, determined to be "safe" and published on government Gazette((approximately 8,000 substances);

Note: Some substances are exempt from new substance notification. A new substance is also subject to notification under ISHL if it is not on ISHL list.

Annual Reporting of General Chemical Substances and PACs

This is a new requirement for manufacturers and importers under amended CSCL. The main purpose of annual reporting is to provide the Japanese government with the information on the volume and uses of existing chemical substances placed on Japanese market. Based on the info received and available knowledge on chemical hazards, the Japanese government may take further regulatory actions against those existing substances by adding them onto different regulatory lists such as the list of priority assessment chemicals or the list of specified chemical substances.

More Info about Japan CSCL
http://www.chemsafetypro.com/Topics/Japan/Japan_CSCL_Chemical_Substance_Control_Law.html

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