Japan promulgated the Cabinet Order for the Partial Revision of the Enforcement Order of the Act on Preventing Mercury Pollution of the Environment

On December 27, 2024, the Japanese Cabinet promulgated the Cabinet Order for the Partial Revision of the Enforcement Order of the Act on Preventing Mercury Pollution of the Environment. In this revision, certain products are newly added to the specified mercury-using  products defined in Article 2, paragraph (1) of the Act on Preventing Mercury Pollution of the Environment, following the addition of mercury-containing products to Annex A, Part I of the Minamata Convention on Mercury (hereinafter the “Convention”) at the 4th and 5th Conferences of the Parties (COPs). This revision addresses the products that were decided to be phased out at COP-4 and COP-5 of the Convention, excluding seven products that have already been regulated under the existing law (which partially came into force on January 1, 2025).

Products to be added and enforcement dates

Under this revision, in Japan, specified mercury-using products including batteries, fluorescent lamps for general lighting purposes, cold cathode fluorescent lamps for electronic displays, and manometers will be subject to the regulatory control in a phased manner from January 1, 2026, through January 1, 2028. Products that are and will be subject to the regulation are summarized as follows.

• Batteries: Button batteries such as silver oxide batteries containing mercury and zinc air batteries have been allowed as exceptions, which will however be regulated (prohibited) from January 1, 2026.
• Self-ballasted fluorescent lamps for general lighting purposes:
  • Until end of 2025: Those with a rated power consumption not exceeding 30 W and a mercury content exceeding 5 mg
  • From January 1, 2026: Those with a rated power consumption not exceeding 30 W
  • From January 1, 2027: Without exception, all the self-ballasted fluorescent lamps for general lighting purposes
• Single-ended compact fluorescent lamps for general lighting purposes:
  • Until end of 2025: Those with a rated power consumption not exceeding 30 W and a mercury content exceeding 5 mg
  • From January 1, 2026: Those with a rated power consumption not exceeding 30 W and a mercury content exceeding 5 mg
  • From January 1, 2027: Without exception, all the single-ended compact fluorescent lamps for general lighting purposes
• Linear fluorescent lamps (LFLs) for general lighting purposes (using halophosphate phosphor):
  • Until end of 2025: Those with a rated power consumption not exceeding 40 W and a mercury content exceeding 10 mg
  • From January 1, 2026: Those with a rated power consumption not exceeding 40 W and a mercury content exceeding 10 mg
  • From January 1, 2027: Without exception, all the LFLs for general lighting purposes
• LFLs for general lighting purposes (using triband phosphor)
  • Until End of 2025: Those with a rated power consumption less than 60 W and a mercury content exceeding 5 mg
  • From January 1, 2026: Those with a rated power consumption less than 60 W and a mercury content exceeding 5 mg
  • From January 1, 2027: Those with a rated power consumption less than 60 W and a mercury content exceeding 5 mg
  • From January 1, 2028: Without exception, all the LFLs for general lighting purposes
• Fluorescent lamps for general lighting purposes (using halophosphate phosphor), other than single-ended compact fluorescent lamps, self-ballasted fluorescent lamps, and LFLs, for general lighting purposes
  • From January 1, 2027: Without exception, all the fluorescent lamps for general lighting purposes (using halophosphate phosphor) will be subject to regulation.
• Fluorescent lamps for general lighting purposes (using triband phosphor), other than single-ended compact fluorescent lamps, self-ballasted fluorescent lamps, and LFLs, for general lighting purposes
  • From January 1, 2028: Without exception, all the fluorescent lamps for general lighting purposes (using triband phosphor) will be subject to regulation.
• Cold cathode fluorescent lamps (CCFL) and external electrode fluorescent lamps (EEFL) for electronic displays
  • Until end of 2025: Those falling under any of the following three conditions are subject to regulation:
    • Those with a mercury content per lamp exceeding 3.5 mg and a length not exceeding 500 mm
    • Those with a mercury content per lamp exceeding 5 mg and a length exceeding 500 mm but not exceeding 1,500 mm
    • Those with a mercury content per lamp exceeding 13 mg and a length exceeding 1,500 mm
  • From January 1, 2026: Without exception, all the CCFLs and EEFLs for electronic displays will be subject to regulation.
• Manometers
  • Until end of 2025: Electric manometers that fall under any of the following conditions are regulated:
    • Macleod vacuum gauges with a maximum measurable pressure exceeding 1,300 Pa and a scale interval exceeding 300 Pa
    • U-tube vacuum gauges with a maximum measurable pressure exceeding 66,000 Pa and a scale interval exceeding 200 Pa
  • From January 1, 2026: Non-electric and electric manometers that fall under any of the following conditions will be subject to regulation:
  • Non-electric manometers (diaphragm manometers capable of measuring temperatures of at least 230 °C with a scale interval not exceeding 5 MPa)
    • Macleod vacuum gauges with a maximum measurable pressure exceeding 1,300 Pa and a scale interval exceeding 300 Pa
    • U-tube vacuum gauges with a maximum measurable pressure exceeding 66,000 Pa and a scale interval exceeding 200 Pa
  • Electric manometers (capable of measuring temperatures of at least 230 °C and used for measuring the pressure of objects that can be liquidized by heat)
    • Those with measurement error for maximum gauge pressure exceeding 1% but less than 3%
    • Those with measurement error for maximum gauge pressure exceeding 3% (subject to limitations on the materials and tube length of such manometers)

Specified mercury-using products

“Specified mercury-using products” are the mercury-using products as defined in the Cabinet Order as those with specific needs for regulatory control. Specified mercury-using products are in principle prohibited from being produced, imported, and exported. However, in the case of the use allowed under the Minamata Convention, their production, import, or export may be allowed subject to license or approval by the Minister of Economy, Trade and Industry.

Related URLs

• Original text of the Cabinet Order for the Partial Revision of the Enforcement Order of the Act on Preventing Mercury Pollution of the Environment:
  https://public-comment.e-gov.go.jp/pcm/download?seqNo=0000279450
• Old and new comparison table reflecting the new Cabinet Order for the Partial Revision of the Enforcement Order of the Act on Preventing Mercury Pollution of the Environment:
  https://public-comment.e-gov.go.jp/pcm/download?seqNo=0000279452
• Official Gazette promulgating the Cabinet Order:
  https://kanpou.npb.go.jp/20241227/20241227g00303/20241227g003030009f.html