Japan's Ministry of Economy, Trade and Industry (METI) has revised import clearance procedures for chemical substances under the Chemical Substances Control Law (CSCL), effective from 1 February 2024. Overseas exporters to Japan must submit specific documents based on the classification of the chemical, with additional amendments to prohibited import products taking effect from 1 June 2024. These changes directly impact supply-chain compliance for chemical shipments into Japan.
Document requirements by chemical classification
For each category of chemical substance—ranging from existing chemicals to new substances—importers must submit corresponding documents at customs clearance. Existing, publicly notified, monitoring, and priority assessment chemicals require a serial number and notification category number. Class I specified chemicals for specific purposes need a copy of the permit, while those for tests and research require Form 1 documents. Class II specified chemicals require Form 2 documents for test/research purposes, and intermediates need a copy of the confirmation notice.
New chemical substance documentation
New chemical substances, including small-volume and low-production-volume types, require a confirmation notice and Form 3 documents. New chemicals pertaining to overseas manufacturers must submit a copy of the notification and Form 4 documents. Polymers under new chemical categories also need a copy of the confirmation notice. Exporters should verify the exact document set for their product's classification before shipping.
Reporting obligations for Class II specified chemicals
When importing Class II specified chemical substances for purposes other than testing and research, the planned import quantity must be reported to METI every fiscal year. If the actual imported quantity exceeds the reported planned quantity, a specified change procedure is required. This obligation applies to all commercial imports of Class II substances and requires careful tracking of annual volumes.
Amendments to prohibited import products from June 2024
From 1 June 2024, METI will implement amendments to Appendix 2 of the CSCL, which aligns prohibited import products with the Customs Tariff Act. Key changes include revising the description for PFOS-based surface treatment agents for electroplating and adding new restrictions for products containing PFHxS or its isomers or salts. Affected product categories include water-repellent textiles, etching agents, surface treatment agents, anti-reflection agents, semiconductor resists, fire extinguishers, and fire-extinguishing agents.
What buyers should watch
Exporters to Japan should review their chemical classifications against the updated CSCL categories and ensure the correct documentation is prepared for customs clearance. For Class II specified chemicals, establish internal tracking systems to monitor annual import quantities against reported plans. Companies dealing with PFOS or PFHxS-containing products must prepare for the June 2024 import prohibition amendments, which expand the scope of restricted items under the Customs Tariff Act.
Source: Read the original report | Published: March 22, 2024