Materials

Chemicals normally fall within the competency of the Ministry of Economy, Trade and Industry (METI), which is involved in the task of harmonising rules regulating chemicals. However, some years ago, the Ministry of Health, Labour and Welfare (MHLW) initiated a discussion on how to label chemical products that could be harmful to people handling them. Unfortunately, MHLW’s work seems to have been conducted in isolation and its new system lacks logic. As an example, products that are not registered in Japan, despite having a CAS (Chemical Abstract Service) number, could now be labelled as harmful since MHLW’s warning labels are based either on the product’s chemical components (rather than on the final substance), or on the most similar substance already registered in Japan. Additionally, it remains unclear whether or not the results of testing conducted in Europe under REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) can be used.

The hazard classification of chemicals may vary in different regions, mainly because the standards and regulations adopted by different regions may differ. For example, Europe adopts the CLP regulation (Classification, Labelling and Packaging), while Japan adopts the GHS (Globally Harmonized System) classification standard.  In addition, even if the same chemical substance has the same proportion in different mixtures, its hazard classification may be different. This is because the overall hazard of the mixture depends not only on the hazard of the single component, but also on the interaction between the components and the specific use of the mixture. Example substance is, Chloroform (CAS No. 67-66-3): In Europe: According to the EU CLP regulations, chloroform is classified as a carcinogen (Carc. 2), a reproductive toxicant (Repr. 2), and a specific target organ toxicant (STOT RE 2). In Japan: According to Japan’s GHS classification standards, chloroform is classified as a carcinogen (Carc. 1B), a reproductive toxicant (Repr. 1B), and a specific target organ toxicant (STOT RE 1) Then, the label also should be different.

Following the production of advanced materials, components and final products, the Japanese industry is generating a steadily growing amount of industrial by-products as well as later down the road end-of-life objects (some of these are considered as hazardous waste under the Basel system and/or as “waste” according to the Japanese system).These by-products and end-of-life objects often contain an important amount of non-ferrous metals (precious metals, technology metals) of which some are considered critical for the industry. Recovering these key metals is therefore key to the Japanese industry while being instrumental in implementing a circular economy approach in Japan.

It is, however, impossible to fully close the loop if waste shipment and treatment in world-class facilities are made difficult by authorities. Indeed the recovery of these metals cannot always be carried out in Japan for valid reasons being for instance that the technology is not available in Japan, the recycling capacity is not sufficient in Japan or the economics of recycling in Japan are less advantageous than recycling in Europe for the benefit of Japanese customers.

Continuing on the same topic, the issue of sustainability in the sector has experience a drastic change in the last couple of years. Japan has committed to become carbon neutral by 2050. Some actions have already been implemented but many other policies also need to be executed. For this EBC Materials Committee this is a very important issues, as the very future of our planet is at stake. The EBC believes that “materials” can play a pivotal role.