[Home](/)/[Resources](/resources)/Japan CSCL Chemical Substances JapanChemical compliance # Japan Chemical Substances Control Law (CSCL): Import Obligations for Electronics Japan's Chemical Substances Control Law (CSCL / 化審法) and the Industrial Safety and Health Law (ISHL / 安衛法) together govern which chemical substances can be manufactured or imported into Japan — and under what conditions. For electronics importers, the key question is whether any substance in your product's bill of materials triggers a pre-import notification obligation or annual volume reporting requirement. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fjapan-chemical-substances-control-law) At a glance Governing act CSCL (化審法) Administrator METI / MHLW / MOE Scope New & existing chemicals Key obligation Pre-manufacture/import notification ## The two laws that govern chemicals in electronics ### CSCL — Chemical Substances Control Law (化審法) The CSCL, jointly administered by METI, MHLW, and MOE, governs the manufacture, import, and use of chemical substances in Japan. It classifies substances into categories ranging from Class I Specified Chemical Substances (effectively banned) through to general existing chemicals. Any company importing a chemical substance not already listed in the existing chemicals inventory must file a pre-manufacture/import notification before the first import. ### ISHL — Industrial Safety and Health Law (安衛法) The ISHL, administered by MHLW, runs a parallel notification scheme for new industrial chemicals. While CSCL focuses on environmental and health risk across the lifecycle, ISHL is primarily concerned with worker safety in manufacturing settings. Both schemes may be triggered simultaneously for the same substance — each has its own notification form, review process, and agency. ### New Chemical Notification (NCN) under CSCL Before manufacturing or importing a new chemical substance (one not listed on the CSCL existing chemicals inventory), the responsible party must submit a New Chemical Notification to METI. The notification includes data on chemical properties, toxicological screening, and intended use. METI reviews the substance and assigns a risk classification before import may proceed. Notification is substance-specific, not product-specific — but the importer of record carries the obligation. ### Priority Assessment Chemicals (PACs) PACs are existing chemicals for which METI has flagged a need for further risk evaluation. Manufacturers and importers of PACs must report annual production/import volumes. If a PAC's risk assessment concludes that it poses unacceptable risk, it can be reclassified as a Monitoring Chemical Substance or a higher-restriction class. Electronics companies should screen their bill of materials against the PAC list annually. ## How to assess your product's chemical obligations 01 Compile a complete bill of materials (BOM) for your product, listing every chemical substance present in components — including substrates, solders, coatings, adhesives, and plastics. Supplier declarations (IEC 62474 format or equivalent) are the starting point. 02 Cross-reference each substance against the CSCL existing chemicals inventory (the 'whitelist'). Substances on the existing inventory are not subject to new chemical notification, though they may still be subject to quantity reporting if classified as Priority Assessment Chemicals. 03 For any substance not found on the existing inventory, determine whether it qualifies as a 'new chemical' under CSCL definitions. If it does, a pre-import New Chemical Notification must be filed with METI before the first shipment can be imported into Japan. 04 Screen all substances against the Priority Assessment Chemicals (PAC) list. Where PACs are present, assess annual import volume thresholds — if you import more than 1 tonne per year of a PAC, volume reporting to METI is required. 05 Prepare Safety Data Sheets (SDSs) in Japanese for any Class I, Class II, or Monitoring Chemical Substances present in your product. SDSs must meet GHS format requirements under ISHL and must be provided to downstream users in the supply chain. ## Frequently asked questions ### Does CSCL apply to finished electronic products, or only to raw chemicals? CSCL primarily targets chemical substances as such — the law is triggered when a chemical substance is manufactured or imported. However, when an electronics product contains a substance not listed on the existing chemicals inventory (a 'new chemical'), the importer of that product into Japan may be deemed to be importing the new chemical and is therefore subject to notification obligations. In practice, most commercial electronics components use well-established chemicals that appear on the existing inventory, but novel materials in advanced packaging, battery chemistry, or specialty coatings are the areas to watch. ### What makes a chemical 'new' under CSCL? A chemical substance is 'new' under CSCL if it does not appear in the existing chemicals inventory maintained by METI. The inventory contains over 20,000 substances. A substance absent from the inventory — including novel synthetic molecules, new polymers, or modified variants of existing substances — must be notified before manufacture or import. There is a simplified notification route for substances imported in volumes below 1 tonne per year with limited environmental exposure. ### How does CSCL relate to the EU's REACH regulation? CSCL and REACH share the same underlying policy goal — preventing harmful chemicals from entering commerce without prior assessment — but the frameworks are structurally different. REACH applies to substances in articles above a 0.1% concentration threshold and operates through the SVHC (Substances of Very High Concern) list. CSCL operates via a positive list of existing chemicals and a notification gateway for new ones. A substance compliant under REACH is not automatically cleared under CSCL. Electronics importers targeting both markets need to run separate substance screening exercises against each framework. ### Who is responsible for filing the New Chemical Notification — the foreign manufacturer or the Japanese importer? The notification obligation under CSCL falls on the entity that imports the chemical substance into Japan — in practice, the Japanese importer of record. Foreign manufacturers cannot file on their own behalf. If you sell finished goods to a Japanese distributor who imports them, that distributor carries the CSCL notification obligation. If you import directly via your own Japanese entity or a customs broker acting on your behalf, the obligation sits with you. It is standard practice to obtain substance declarations from component manufacturers before import and to request indemnification or joint notification support where new chemicals are identified. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇯🇵 Japan roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇯🇵 Japan compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/42-japan-pse-marking-ecommerce-electronics-sellers)[Prefer to read? 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