Mitsui Chemicals

Product Stewardship

Strengthening the Management System

Reinforce Governance in a Bid to Fully Comply with All Newly Enacted and Amended Laws

Toward the achievement of the World Summit on Sustainable Development (WSSD) targets, each country is promoting the enactment of new or revised laws. Having greatly changed the whole concept of the chemical management system, the European Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) system has been adapted by each country while continuing to be introduced into many countries. Meanwhile, regarding the issue of taking measures against existing chemicals, even those countries that are at the forefront of chemicals management are proceeding to make changes to their laws.

In accordance with the Act on the Registration and Evaluation, etc. of Chemical Substances (K-REACH) that came into effect in Korea in 2015, the Mitsui Chemicals Group reported its manufactured and imported tonnage, and is responding in a planned manner towards the June 2018 registration deadline for chemicals that are subject to registration. In addition, K-REACH abolishes the system used until now that registers only some chemical products, and will be revised to register all chemical products manufactured and imported in volumes of one ton or more per year, in the same way as European REACH. This system will be enforced from January 2019. We will take advantage of our European REACH and other experience in responding in a planned manner to this revision.

In the United States, the Toxic Substances Control Act (TSCA) was revised in June 2016. Coinciding with the "reorganization" of the list of existing chemical substances, we made notification of the substances manufactured and imported over the past 10 years.

Through active participation in industry initiatives, such as those of the Japan Chemical Industry Association (JCIA), and through close exchanges of information with local consultants, the Mitsui Chemicals Group quickly obtains the regulatory information from each country. At the same time, the Group works to ensure thorough compliance. Moreover, in 2017 we established an organization to accurately collect local legal and regulatory information through our affiliates. As part of this move, we held a legal and regulatory expert committee to exchange information that was jointly attended by experts in law and regulation from our European, American, and Chinese affiliates (MITSUI CHEMICALS EUROPE GmbH, MITSUI CHEMICALS AMERICA, INC., SDC Technologies, Inc., MITSUI CHEMICALS (CHINA) CO., LTD., TAIWAN MITSUI CHEMICALS, INC.). In fiscal 2018, we plan to expand this system to Southeast Asia.
Led by the Global Chemical Regulation Compliance Team, in which business divisions and all corporate divisions participate, Mitsui Chemicals investigated and rapidly implemented Group-wide response measures in divisions across the company. Going forward, we will continue to respond in a planned manner to newly enacted and revised laws and regulations, including REACH of Europe, K-REACH of Korea, and TSCA of U.S., manage the progress of this response, and ensure full compliance.

Thorough Chemicals Management after Product Release to Market

The promulgation of national laws, including European REACH, marks the beginning of the registration of products and chemical substances, but the management of risks, such as the imposing of restrictions and the granting of approvals by regulatory authorities after registration, does not end after a product is released to the market. Regulatory requirements after launch to the market are also becoming more sophisticated and complicated, and it is essential to promptly and precisely implement appropriate responses.

We respond to changes in, for example, risk assessments and risk management from a range of perspectives that include a variety of changes after release to the market, such as changes in laws and regulations; the addition of regulated substances; the ascertaining of new hazard information; changes of product application; changes in raw materials/manufacturing methods; and toxicity based on internal regulations. It is thought, however, that the responses to be made will become progressively more complex in the years to come due to the regulations covering chemicals becoming even more stringent, as a result of revisions to the law and the formulation of new laws, and due to progress made in the evaluation of substances, including under European REACH. To better respond to such a variety of changes of this kind, we will work to reinforce the chemicals management system and ensure management when changes are made.

Build a Structure That Properly Conveys Information That in Turn Complies with Diversifying Regulatory Requirements

Information on all the products, raw materials and chemical substances handled by Mitsui Chemicals is controlled in an integrated manner by a chemical product safety information system (SAP–EHS). Through coordination between this system and mission-critical processes, we have reinforced both the expeditious provision of information to customers and compliance relating to chemical laws and regulations, such as the confirmation of legal compliance with domestic and foreign regulations, the management of production/import quantities, and the automatic creation of safety information, such as multilingual SDS, product labels, MSDSplus*1, etc. Going forward, we will also comply with chemSHERPA*2, a new scheme for conveying information about chemical substances contained in products.
To enable us to share product-related regulatory and safety information, we introduced this system to some affiliates in Europe, the United States and China and have been carrying out system upgrades. In addition, the automation of SDS creation was completed in China, following on from Europe, the United States, South Korea and Taiwan. System compatibility with major export destination countries was also completed.
In addition to advancing the development of this system to affiliates in Japan and overseas in the years to come, we will strive to communicate information that will enable us to respond to diversifying regulations and customer demands. Specifically, in the case of the overseas version of SDS, we will assign expert staff to carry out locally the confirmation of the detailed applicable laws of each country and strengthen SDS creation and supply systems as the Mitsui Chemicals Group.

*1
MSDSplus:
A basic information sheet used to communicate information about chemical substances contained in products, as recommended by the Joint Article Management Promotion-consortium (JAMP).
*2
chemSHERPA:
Chemical information Sharing and Exchange under Reporting Partnership in supply chain. A scheme for conveying information about chemical substances contained in products. The Ministry of Economy, Trade and Industry is developing and promoting this scheme in aims of having the scheme utilized globally.