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On 1 September 2025, Japan’s Ministry of Economy, Trade and Industry (METI) released draft to amend provisions of Export Approval for Chemical Substances under Export Trade Control Order. Consultation notice was published on the Japan’s e-GOV Public Comment Portal. The Japanese Export Trade Control Order is a key regulation under the Foreign Exchange and Foreign Trade Act.

Export Trade Control Order

Under the Japanese Export Trade Control Order (Cabinet Order No. 378 of 1949), the export of certain chemical substances is strictly regulated through an export approval system administered by the Ministry of Economy, Trade and Industry (METI). This framework aligns Japan with international obligations under the Rotterdam and Stockholm Conventions and the Chemical Substances Control Law (CSCL). Exporters must obtain prior authorization when shipping hazardous chemicals such as pesticides, persistent organic pollutants (POPs), mercury compounds, asbestos, and PFAS, including mixtures, formulations, and even finished products containing these substances. The system ensures that Japan fulfills its role in safeguarding human health, the environment, and international security by preventing the uncontrolled transfer of dangerous chemicals.

Provisions drafted under Consultation Notice

Revised provisions are summarised in below table:

Comment Period and Enforcement Dates

Stakeholders are informed to submit comment on this draft provisions by 2 October 2025. While METI has not published the enforcement dates yet.

On 20 August 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI) and Ministry of the Environment (MoE) jointly released the draft amendments to guidelines under Chemical Substances Control Law (CSCL). Ministry released the draft notification on the Japan’s e-GOV Public Comment Portal. The ministries plan to update these operational guidelines in light of the 2025 assessment of the 2017 CSCL amendment and plans for chemical substance management in the future. The March 29, 2019 notification on managing by-product Class I Specified Substances will also be revised.   

Key Amendments from draft notification

Article 1 – Impurities containing Class I Specified Substances:

• Previously, rules only applied when Class I Specified Substances were present as by-products.
• Now, rules will also apply when they are present as impurities (broader definition, including by-products).

Article 2 – Structural Changes and Clarifications:

1. Restructuring:
• Establish a new section "1. Common Provisions" to consolidate rules that apply across the entire guideline.
2. Clarifications:
• Clarify treatment of anhydrous vs. hydrated substances.
• Clarify definitions of terms for organic polymers.
3. Existing vs. New Substances:
• Some substances previously excluded from being treated as "new" will now be explicitly treated as existing chemical substances, with reference to specific provisions in the law (Article 2, paragraphs 4, 5, 7).

Article 3 – Existing Chemicals:

• Revision of the definition of "existing chemical substances" with necessary updates.

Comment Period and Enforcement Dates