On 7 February 2025, Japan’s Ministry of Economy, Trade and Industry (METI), in collaboration with the Ministry of Health, Labour and Welfare (MHLW) and the Ministry of Environment (MOE), released a draft notice for the revision of the PAC list and monitoring procedures for FY2024. This update was published on METI’s portal on the same day. Priority Assessment Chemical Substances (PACS) are regulated under Japan’s Chemical Substances Control Law (CSCL). 

 

Background: PACs & Monitoring 

PACs are substances whose potential for long-term harm to humans or to plants and animals that inhabit human environments is not entirely apparent. Therefore, in order to protect living organisms, companies that manufacture or import these chemicals in amounts exceeding 1 Tonne Per Annum (TPA) must submit annual reports to assure adherence to METI regulations and to promote safety and responsibility in handling of chemicals.  

 

Key Insights from the draft notice 

In the draft notice, METI has proposed: 

  • To delist two chemicals from the PACS list, as their annual reports for 3 consecutive years (FY 2020-2023) have indicated released volumes of less than 1 TPA to the environment, indicating that they no longer pose a risk to living organisms.  

  • To monitor six chemicals from the PACS list for quantity monitoring for the coming years due to their potential environmental impact. These substances have reported manufacturing or import quantities of less than 10 TPA or environmental releases of less than 1 TPA.  

 

Enforcement Dates 

From the draft notice, it is evident that enforcement will be effective from April 2025.