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 operational notice on the Handling of Chemical Substances Containing Class I Specified Chemical Substances as Impurities under the Chemical Substances Control Law (CSCL). The revision updates management procedures to align with the government’s circular economy goals and Best Available Technology (BAT) principles. Class I specified substances present as by-products or impurities are no longer automatically regulated as Class I substances if managed according to BAT. However, manufacturers and importers must ensure information communication through SDS and appropriate control of impurities, especially in recycled plastic materials. For substances like HCB, PCBs, and SCCPs, management below established control limits is accepted without separate justification. Firms must continue efforts to reduce impurity levels and report management practices to all three ministries.
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