Detailed Explanation of Japan's Designated Substance Reporting Requirements for 2025

Recently, the Ministry of Economy, Trade and Industry (METI) of Japan issued an important notice under the Chemical Weapons (Prohibition) Act, requiring relevant enterprises to submit reports by September 30, 2024, on the estimated production, extraction, refining, and use of designated substances in 2025. It aims to comply with the provisions of the Chemical Weapons Convention, which was established in 1992 and ratified in 1995. Japan has been steadily implementing the obligations, including reporting and accepting international inspections.

Reporting Items

• Estimated production, extraction, refining, and use of Class I designated substances in 2025.
• Estimated production of Class II designated substances in 2025

According to the notice, enterprises that meet any of the following conditions need to submit reports on the estimated production and usage of substances for 2025:

For Class I designated substances:

• Estimated production, extraction, refining, or use of the designated substance exceeds the reporting threshold in 2025.
• Production, extraction, refining, or use of the designated substance exceeded the reporting threshold in any year from 2021 to 2023.
• A report on the estimated production, extraction, refining, and use has already been submitted in 2024.

For Class II designated substances:

• Estimated production of the designated substance exceeds the reporting threshold in 2025.
• Production of the designated substance exceeded the reporting threshold in 2023.
• A report on the estimated production has already been submitted in 2024.

Furthermore, if the estimated production, extraction, refining, or use is below the reporting threshold but is later expected to exceed it, enterprises must also submit a report on the estimated quantities 30 days before exceeding the threshold. This requirement also applies to substances produced as by-products.

Designated substances

	Toxic substances	Raw material substances
Class I designated substances	Amiton:O,O-Diethyl S-[2-(diethylamino)ethyl] phosphorothiolate and corresponding alkylated or protonated salts PFIB: 1,1,3,3,3-Pentafluoro-2-(trifluoromethyl)-1-propene (also known as: Perfluoroisobutylene; Octafluoroisobutylene) BZ:3-Quinuclidinyl benzilate	Compounds containing phosphorus atoms not bonded to carbon, but bonded to alkyl groups with no more than three carbons, except for the substances listed in items (1) to (4) of the first column and the fourth column, and: Dichlorvos: O,O-Diethyl S-(2-(ethylthio)ethyl) phosphorothioate Dialkyl (methyl, ethyl, n-propyl, or isopropyl) amino phosphonodihalides (with the alkyl groups having no more than three carbons) Dialkyl (methyl, ethyl, n-propyl, or isopropyl) amino phosphoric acid dialkyl (methyl, ethyl, n-propyl, or isopropyl) esters (with the alkyl groups having no more than three carbons) Arsenic trichloride 2,2-Diphenyl-2-hydroxyacetic acid: Diphenolic acid; Diphenylglycolic acid Quinuclidin-3-ol Dialkyl (methyl, ethyl, n-propyl, or isopropyl) aminoethyl-2-chloride (with the alkyl groups having no more than three carbons) and corresponding protonated salts Dialkyl (methyl, ethyl, n-propyl, or isopropyl) aminoethyl-2-alcohol (with the alkyl groups having no more than three carbons) and corresponding protonated salts, excluding dimethylaminoethanol and its protonated salts, and ethylaminoethanol and its protonated salts Dialkyl (methyl, ethyl, n-propyl, or isopropyl) aminoethyl-2-thiol and corresponding protonated salts Dithioerythritol: Bis(2-hydroxyethyl) sulfide; Thiodiglycol Pinacolyl alcohol: 3,3-Dimethylbutan-2-ol
Class II designated substances	Phosgene: Carbonyl dichloride Cyanogen chloride Hydrogen cyanide Chloropicrin: Trichloronitromethane	Phosphorus oxychloride: Phosphoryl chloride; Phosphorus trichloride oxide Phosphorus trichloride Phosphorus pentachloride Trimethyl phosphite Triethyl phosphite Dimethyl phosphite Diethyl phosphite Sulfur monochloride Sulfur dichloride Thionyl chloride: Sulfur dichloride oxide; Sulfuryl chloride Ethyldiethanolamine Methyldiethanolamine Triethanolamine

Reporting thresholds

				Reporting threshold
				Quantity threshold	Concentration Threshold (Converted by Weight)
Class I designated substances	Production/Use	Toxic substances	BZ	1kg	Production: none Use：＞10kg：1%    1kg -10kg：10%
			Non-BZ substances	100kg	Production: none Use：＞1t：1%      100kg -1t：10%
		Raw material substances		1t	Production: none Use：30％
Class II designated substances	Production			30t	None

Note: If the concentration threshold column shows "None," reporting is required regardless of the amount.

Circumstances Requiring Submission of a Change Report

If the actual production, extraction, refining, or use is anticipated to exceed the previously projected quantities, enterprises must submit a change report 30 days before the following circumstances occur:

1. The estimated increase exceeds twice the reported amount (applicable to both Class I and Class II designated substances).
2. The estimated increase exceeds ten times the reporting threshold (applicable to Class I designated substances).
3. The estimated increase exceeds 200 tons (applicable to Class II designated substances).

Through these measures, the METI continues to strengthen the regulation of chemical substance, ensuring compliance with domestic and international regulations and chemical safety.

For details on the report format, see the following website:

https://www.meti.go.jp/policy/chemical_management/cwc/2025_kaheihou_yoteisuuryou_todokedekigen.pdf

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Further Information

METI