JP CSCL — Designation of Dechlorane Plus and UV-328 as Class I Specified Chemical Substances
ENFORCEMENT TIMELINE
Enforcement scheduled for Autumn 2025
Overview
Following a decision at the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants, Japan is designating the flame retardant Dechlorane Plus and the UV stabilizer UV-328 as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL). Once designated, manufacturing and import of these substances will, in principle, be prohibited unless specifically permitted, and the import of products containing them, including automotive parts, electrical and electronic products, and molded resin products, will also be comprehensively banned.
Enforcement Timeline
May 2023: At COP11 of the Stockholm Convention, the elimination of Dechlorane Plus and UV-328 is decided and added to Annex A.
November 2024: Cabinet approval and promulgation of amendments to the CSCL enforcement order.
Autumn 2025 (scheduled): The designation as Class I Specified Chemical Substances takes effect, and the ban on manufacturing, import, and import of products containing these substances becomes effective.
Business Impact
Japanese companies in the automotive, electrical and electronics, machinery, resin, and coatings industries need to quickly identify and manage the use of both substances across their own products and supply chains, using tools such as chemSHERPA and safety data sheets. Importing or selling parts or products containing the regulated substances without obtaining non-use certifications or switching to alternative flame retardants or UV stabilizers constitutes a violation of the CSCL and carries the risk of recall orders and legal penalties.