Japan has developed vast knowledge and expertise in processing and recycling materials and is at the forefront of many technologies, such as those used to produce rechargeable batteries for hybrid vehicles, nanotechnologies for manufacturing semiconductors, and products related to environmental technology.

These advanced technologies depend on key raw materials and Japan’s ability to secure a stable, high-quality supply. It is, therefore, of the utmost importance that Japan adopts a strategy based on security of supply at competitive prices, which can only be achieved by allowing overseas suppliers unrestricted access to its domestic market.

The EU-Japan Economic Partnership Agreement has removed tariffs in the materials sector. This will give European suppliers a competitive edge in the Japanese market. Moreover, it will give a boost to Japanese industries able to source key materials at lower prices. However, not all imports will benefit from tariff removal, since many European companies have a global presence and not all their production is conducted within the EU.

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, which entered into force on 1 July 2016, 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.

One example of the issues raised by the MHLW approach relates to a European cement containing aluminium oxide (CAS 1344-28-1). According to the MHLW list, any product containing more than 1% of aluminium oxide must have a label warning how it should be handled. The problem arises from the fact that this particular substance (CAS 1344-28-1) is not regarded or registered as hazardous in Europe. As a result, the same product ends up with a number of non-homogeneous labels, pictograms and safety data sheets that create unnecessary doubts and confusion about its safety.

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. With the announcement of Prime Minister Suga that Japan will be carbon neutral by 2050, many companies in the metal industry are now looking at how to support this. Several European companies have already introduced, not only policies, but actual actions. For this EBC Materials Committee this is a very important issues, as the very future of our planet is at stake.

Key issues and recommendations


Mr. Eduard Gabric
President & Representative Director
VDM Metals Japan K.K.
Daido Seimei Kasumigaseki Bldg. 7F.
1-4-2 Kasumigaseki
Chiyoda-ku, Tokyo 100-0013
Tel: +81-3-6205-4341
Fax: +81-3-6205-4342

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March 11 (Monday)17:30~hybrid
June 10 (Monday)17:30~hybrid
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December 16 (Monday)17:30~hybrid