Japan Expands CSCL Hazard Information Reporting to Include “Poor Biodegradability” for Class II Specified Chemical Substances 
On May 29, 2026, Japan’s Ministry of Health, Labour and Welfare (MHLW); Ministry of Economy (MOE), Trade and Industry; and Ministry of the Environment (METI) jointly promulgated and enforced partial revisions to the “Ministerial Ordinance on the Reporting of Hazard Information” and the “Administrative Guidance on the Reporting of Hazard Information” under the Chemical Substances Control Law (CSCL). Article 41 of the CSCL requires manufacturers and importers of chemical substances to report to the government when they obtain knowledge indicating certain hazardous properties—such as biodegradability, bioaccumulation, or toxicity—of substances they manufacture or import. Until now, hazard information had been accepted only in paper form. To promote the digitalization of administrative procedures, electronic submission through the government’s online portal “e‑Gov” is now permitted.
Hazard Information Reporting Obligations Under CSCL Article 41
Business operators that manufacture or import chemical substances must report to the three ministries within 60 days when they obtain new knowledge indicating certain hazardous properties—such as poor biodegradability, high bioaccumulation, or toxicity—of the substances they manufacture or import. Reporting requirements differ depending on the classification of the chemical substance, and existing hazard information is categorized as “mandatory reporting,” “best‑effort reporting,” or “voluntary reporting,” depending on the applicable criteria. Knowledge obtained before manufacturing or import begins is treated as “voluntary reporting,” regardless of its content.
The scope of reportable knowledge is not limited to test results generated at facilities compliant with the Chemical Substances GLP. Test results from non‑GLP facilities are also included. Specifically, results from tests conducted in accordance with methods specified in relevant administrative notices or OECD Test Guidelines—such as biodegradability, bioconcentration, chronic toxicity, and effects on reproductive capability and subsequent generations—are subject to mandatory or best‑effort reporting.
Below are the main elements of the revision :
Partial Revision of the Ministerial Ordinance on Hazard Information Reporting
To enable electronic submission of hazard information, the required content of reporting forms has been clarified. In addition, because Monitoring Chemical Substances are already known to possess poor biodegradability and high bioaccumulation, the Ordinance now explicitly states that such knowledge is excluded from reporting requirements.
Partial Revision of the Administrative Guidance on Hazard Information Reporting
Previously, knowledge related to the “poor biodegradability” of Class II specified Chemical Substances was excluded from reporting. However, following the 2009 CSCL amendment, Class II specified Chemical Substances are no longer limited to those with poor biodegradability. Accordingly, such knowledge is now newly designated as reportable.
Other Revisions and Related Matters
In conjunction with these revisions, the “Guideline for Reporting Hazard Information Under CSCL Article 41” were also updated. The Guideline now clearly requires that hazard information reports be “submitted separately for each substance and each property.”
EnviX’s comment
For business operators, the 60‑day period may feel short when considering the time needed to review the finalized study report (new knowledge) received from a testing institution and then prepare the hazard information report. Therefore, companies should establish a system in which testing institutions share draft reports or preliminary results (interim findings) on an ongoing basis. Once it becomes likely that a hazardous property will be identified, companies can begin preparing the submission documents, enabling prompt filing after receiving the final test report.
Furthermore, because the revision now allows online submission via e‑Gov, operators can avoid the time and effort associated with printing and mailing documents. This is expected to facilitate faster and smoother reporting within the 60‑day deadline.
Reference URLs
- Reporting of Hazard Information (METI)
https://www.meti.go.jp/policy/chemical_management/kasinhou/todoke/harmful_index.html - Results of Public Consultation on the Draft Partial Revision of the Ministerial Ordinance and Administrative Guidance
https://public-comment.e-gov.go.jp/pcm/1040?CLASSNAME=PCM1040&id=595126055&Mode=1 - Ministerial Ordinance on Hazard Information Reporting
https://www.meti.go.jp/policy/chemical_management/kasinhou/files/about/laws/laws_r08052936_0.pdf - Chemical Substances Control Law
https://laws.e-gov.go.jp/law/348AC0000000117/20260701_508AC0000000022?occasion_date=20260701
