Japan has published draft "emission factors" that will be used as a benchmark to determine whether new small amount and low-volume chemical substances are exempt from notifications and risk assessments.
From January 2019, production and import of these substances will be regulated based on emissions rather than volumes of production/importing, according to current proposals.
This novel approach reflects the increasing variety of substances used in Japan, often in small batches. It seeks to maintain a precautionary approach to regulation, while addressing bottlenecks in production caused by unnecessary limits.
The factors are numbers used to calculate the estimated amount of emissions for particular uses. The volume of these would be calculated according to the volume of imports/manufacture multiplied by the emission factor. The factor is based on the proposed use reported by a company.
For example, the use of a substance in paints would be given an emission factor of 0.9. This means a company importing/manufacturing one tonne is estimated to result in emissions of 900kg.
The emission factors vary greatly depending on use. The proposed list covers 48 different uses.
No emission factor has been set for 'other ingredients or additives' to promote innovation by industry, according to the ministries' announcement.
As previously, where several companies want to manufacture/import such substances and the total annual volume exceeds the national limit, the government would adjust the volumes permitted to each company so they remain compliant.
Under the proposals the permitted volumes for emissions will remain the same those for manufacturing/imports.
Consultation on the draft closes on 27th July. Finalised emission factors will be published in August.
More details available on CW+AsiaHub