Efforts to promote scientific risk-based management of the entire chemical substance life cycle and establish mechanisms for communicating the information necessary for proper chemical substance management are being made globally, and new laws and regulations are being enacted or revised to reflect the actual situation in each country. In response to such changes in the business environment and socio-economic conditions, the industry is now being required to comply more closely with laws and regulations in Japan and overseas.
JCIA collects, analyzes, and shares information on trends in domestic and overseas chemical product regulations, consolidates opinions and recommendations from the industry, and actively makes policy proposals to the competent administrative authorities, etc., to support smooth enforcement of laws by the government and proper compliance with corporate law and regulations. In particular, with regard to compliance with domestic law and regulations, JCIA actively participates in various government committees and review meetings as a representative of the chemical industry and offer opinions to the competent authorities.
Compliance with Japanese domestic laws and regulations
In the area of compliance with domestic laws and regulations, the Domestic Law WG discusses the direction that revision of laws related to major domestic regulations of chemical substances should take, identifies problems in the application of the law, considers countermeasures, and continuously offers opinions to, and engages in dialogue with, the regulatory authorities. JCIA is making proposals on how to revise the law on the basis of scientific evidence, as well as how to apply the law on the basis of actual conditions in the industry.
Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Chemical Substances Control Law: CSCL)
The Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (hereinafter referred to as the "CSCL") is a law intended to prevent contamination of the environment by chemical substances that may damage human health or interfere with the habitat or growth of animals and plants. It is roughly divided into three parts: "preliminary review of new chemical substances," "continuous control measures for chemical substances after launch," and "regulations and measures that take into account the properties, etc. of chemical substances." The latest major amendment was issued on June 7, 2017 (2017 Law No. 53) and fully enforced on April 1, 2019 (2019). This law will be reviewed every 5 years after the enforcement of the revision. JCIA is consolidating its members’ opinions on the revision of the law and offering opinions to the competent authorities.
Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof (Pollutant Release and Transfer Register (PRTR) Act)
The PRTR Act is a law intended to promote improvement of voluntary control of chemical substances by business operators and prevent problems in environmental conservation, and it establishes a system with two main pillars: the Pollutant Release and Transfer Register (PRTR), which is a countermeasure against the emission and transfer of specific chemical substances to the environment, and the Safety Data Sheet (SDS), which provides information on the properties and handling of chemical substances by business operators. JCIA is consolidating its members’ opinions on the revision of the law and offering opinions to the competent authorities.
Appropriate response to introduction of GHS
JCIA has served as secretariat for the revision of the Japanese Industrial Standards (JIS) related to the GHS, which are referenced in the relevant Japanese laws*. Through the GHS WG, JCIA has consolidated its members' opinions on the revision and is making efforts to see that those opinions are reflected in the JIS. The most recent GHS-related JIS are the two announced on May 25, 2019: JIS Z 7252:2019 (Classification of Chemicals Based on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)) and JIS Z 7253:2019 (Hazard Communication of Chemicals Based on GHS – Labeling and Safety Data Sheet (SDS)). Preparation of labels/SDSs on the basis of the pre-revision JIS will be allowed as a temporary measure until May 24, 2022.
* Following laws
-Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof
-Industrial Safety and Health Act
-Poisonous and Deleterious Substances Control Act
Compliance with overseas laws and regulations
In the area of compliance with overseas laws and regulations, regional review teams consisting of experts from member companies have been established within the Overseas Laws WG for the regions of Europe, East Asia, Southeast Asia, the Americas and the others, to discuss issues such as chemical product regulations in each region and formulate/implement countermeasures.
Overseas laws and regulations
With regard to chemical control regulations in Europe, East Asia (China, Korea and Taiwan), ASEAN countries, India, the Americas, and other regions, JCIA monitors trends in laws and regulations governing all aspects of the life cycle of chemical products, from manufacture/import to disposal/recycling, taking into consideration the transmission of information in the supply chain, and then shares information with members, discusses countermeasures, and offer opinions to the authorities when necessary. In addition to grasping the latest trends in national standards related to GHS and providing information to members, JCIA consolidates the opinions of member companies and offers opinions to the administrative authorities. In cases where the impact is not limited to Japanese companies, we are working with local industry associations (ACC, Cefic, SCIC, etc.) to create position papers to support regulatory advocacy, and we are appealing to local authorities through these local industry associations. In addition, we are exchanging information and opinions with the Ministry of Economy, Trade and Industry and request their involvement when necessary.