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Japan to Introduce a New Numbering System for Chemical Substances Subject to PRTR, Along with Changes to Substance Lists

Earlier in December 2020, the Japanese authorities opened a public consultation [1] on adjustments to the lists of substances subject to the Pollutant Release and Transfer Register (PRTR) Law, which proposed to increase the number of Class 1 substances and Class 2 substances from 462 to 516 and from 100 to 134.

Under the PRTR framework, businesses handling Class 1 substances are required to estimate and report the release and transfer of such substances on a regular basis. Both Class 1 and 2 substances are subject to SDS and labelling requirements under the GHS framework.

Since substances in the original lists are ordered by kana alphabetic order, the proposed revision to designated substances, which includes both additions and deletions, will inevitably make them out-of-order.

Therefore, a proposal was also made to assign a number to each substance, so that their numbers will not be changed due to any deletion or addition. Businesses will be required to state the number in SDSs. This proposed change will also make it more convenient for businesses to check whether they need to fulfill obligations under the PRTR framework for any substances.

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