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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