1. Philosophy and Advancement Structure

Under its sustainability promotion scheme, the JSR Group’s Environment, Safety and Quality Committee promotes measures pertaining to chemical management by formulating promotion items and concrete action plans for such items.

(1) Chemical Management Basic Policies

In light of recent global trends in chemical management, JSR has established the following three policies in its environment and safety management organization by which chemical management is implemented.

• 1. Instead of hazard-based management^*1, we will endeavor to implement risk-based management^*2.
• 2. We will strive to manage our entire supply chain by utilizing a globally standardized method.
• 3. We will strive to comply with regulations and promote self-motivated initiatives to ensure the safety of our products.

*1 Hazard-based management: Management based solely on the hazardous properties of substances

*2 Risk-based management: Management based on exposure to the hazardous properties of substances

(2) Chemical Management Advancement Structure

Overview of the advancement structure

• Please see the “Responsible Care” 2. RC Advancement Structure

JSR’s chemical management structure is advanced by centering on compliance with domestic laws and support of exports by the Corporate Dept., as well as chemical management by local subsidiaries abroad. By capturing trends in environmental changes and tightening of regulations both within and outside of Japan early, JSR has been able to make systematic approaches.
Starting in 2019, we established a dedicated chemical products management division. within the Elastomer Products Div., in which there is particularly significant global customer expansion, to support the rapid tightening of regulations abroad and new legislations in various countries. In the Corporate Div. as well, we launched an overseas legal management organization to broadly collect legal information from overseas, such as from industry organizations, and promptly share information with all of JSR, including group companies and local subsidiaries.
At JSR, we will continue to support future domestic and international trends and business expansion by constructing systems flexibly.

2. Voluntary Approaches to Systematically Reduce Toxic Chemicals

JSR systematically implements approaches to reduce and eliminate toxic chemicals starting in the product design stage. Target chemical substances that should be managed include chemicals that are listed in laws and regulations of various countries as well as in customers’ management standards, of course, and also general chemicals that are not listed in regulations. For all of these chemicals, specialists implement reviews during each step, from raw materials procurement to design, development, trial manufacture, customer evaluation, and commercialization. Doing so allows us to build a mechanism that minimizes the risks that JSR products have on people’s health and the environment.

(1) Response to Regulations of Various Countries and Customers’ Standards

Substances of which the manufacture and use are prohibited or restricted in the laws of major countries are investigated in detail starting with the raw materials selection stage, and their use, byproducts and mixing in products is strictly managed. The lists that we adhere to are as shown in *1. Among these, 1) to 6) are those for which use in JSR materials/products is prohibited. Those in 7) to 15) are those for which risks are evaluated by intended use when reviews are conducted in the development stage, and for which the possibility of use and necessity of review of alternative substances are confirmed.

In recent years, regulatory laws on chemicals have been legislated/amended in various countries across the world. As such, JSR confirms the regulated substances in applicable countries and checks their usage restrictions in a framework for reviewing commercialization, in response to expansion of countries to which our products are exported.

*１ List of major chemical substance regulations subject to survey

1）

(Japan) Act on the Regulation of Manufacture and Evaluation of Chemical Substances Class I Specified Chemical Substances

2）

(Japan) Article 55 of Industrial Safety and Health Act and Article 16 of Enforcement Order of the Industrial Safety and Health Act (Harmful Substances, etc., Prohibited for Manufacturing, etc.)

3）

(Japan) Article 2 of Act on Special Measures against Dioxins

4）

(Japan) “Specified Poisonous Substances” as specified in the Poisonous and Deleterious Substances Control Act and Cabinet Order for the Designation of the Poisonous and Deleterious Substances

5）

(UN) Annexes A, B, and C of Stockholm Convention on POPs

6）

(US) Toxic Substances Control Act (TSCA) Prohibited or Restricted Substances in Section 6

7）

(Japan) Act on the Regulation of Manufacture and Evaluation of Chemical Substances Class II Specified Chemical Substances and Monitoring Chemical Substances

8）

(EU) ELV Directive

9）

(EU) RoHS Directive Annex II

10）

(EU) POPs Regulation Annex I

11）

(EU) REACH Regulation Candidate List of SVHC for Authorization and Annex XIV (Authorisation List)

12）

(EU) REACH Regulation Annex XVII (Restricted Substances)

13）

(EU) Medical Devices Regulation (MDR) Annex I 10.4 Chemical Substances

14）

Global Automotive Declarable Substance List (GADSL)

15）

IEC 62474 DB Declarable substance groups and declarable substances

(2) Approaches to Reducing Toxic Substances Across All Chemicals

Even for chemical substances not regulated by law, JSR implements verifications of toxicity during reviews, such as during the raw materials selection stage, design stage and prototype stage, regardless of whether it is an existing chemical substance or new chemical substance. In cases where it is judged as being necessary, JSR also establishes measures such as limiting use. In recent years in particular, JSR has been implementing investigations and analyses of substance information, safety information and country registration information for impurities found in existing chemical substances in the raw materials selection stage. This is part of an effort to strengthen checks to make sure that raw materials containing harmful substances and deleterious substances are not used erroneously.
For substances where there are concerns regarding continuity of future use due to the chemical structure of the substance or trends in risk evaluations by country, our Chemical Products Management Dept. regularly gathers information and makes the business departments and R&D Dept. aware that such substances are substances of concern for which substitution and disuse should be examined starting in the design stage. Their elimination is reviewed in reviews leading up to commercialization. (See diagram below)

Scheme for Confirming/Removing Chemicals of Concern/Toxic Chemicals Applied to All Chemical Substances Starting in the Design Stage

Note: This diagram features only contents of support related to chemical products. In each review, however, quality, specifications, manufacturing techniques, etc. are also checked simultaneously.
"Chemical Management T" under "Department in charge" represents the Chemical management Team in the Environment Dept. and the Chemical Management Team in Technology Management Dept., Elastomer Products.

3. Compliance

(1) Response to Chemical Product-related Domestic Laws and Regulations

In 2017, the Chemical Substances Control Act in Japan^*3 was amended, and the revised portion of this Act which is concerned with the confirmation system used for low volume new chemical substances came into effect in 2019. With regard to the new requirements introduced by the revisions, e.g., that use certificates be submitted for each substance, JSR took steps to ensure that there have been no problems with any of our applications since immediately after the revisions have gone into effect. In addition, we have made advance preparations and are systematically undertaking measures aligning with the amendment of the Law concerning Pollutant Release and Transfer Register in Japan^*4, and to support expansion of substances targeted for management as specified in the Industrial Safety and Health Act in Japan, which are anticipated to take effect in 2022 or 2023.

*3 Act on the Regulation of Manufacture and Evaluation of Chemical Substances in Japan

*4 Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof in Japan

(2) GHS Compliance and Provision of SDS for All Products

1) Provision of SDS^*5 for All Products

JSR has voluntarily adopted a policy of providing customers with environmental and safety information by preparing SDS not only for products subject to legal obligations and products containing hazardous substances, but for all products which contain polymers. All SDS prepared by JSR are in compliance with JIS Z 7253, the Industrial Safety and Health Act in Japan, the Law concerning Pollutant Release and Transfer Register in Japan, and the Poisonous and Deleterious Substances Control Act in Japan.
Furthermore, in order to provide customers with SDS that contain the most accurate information possible about each product, we were early adopters of an SDS electronic data management system, which we have operated since its creation in 2002. This system includes user management, chemical substance database management, creation support, and publication (revision) history, and it allows us to accurately and quickly provide environmental and safety information related to JSR products.

*5 Safety Data Sheet: Documentation listing the names, respective hazards and toxicities, etc., of substances contained in chemical products in order to ensure their safe handling

2) GHS Compliance

GHS^*6 is as an international standard for (a) classification of chemical products according to hazard and toxicity; (b) labeling on product packaging and containers; and (c) documentation and provision of details in the SDS.

In Japan, the Industrial Safety and Health Act and the Law concerning Pollutant Release and Transfer Register stipulate mandatory application of GHS to the labels and SDS of products containing GHS-designated chemical substances, with GHS classification stipulated under JIS Z 7252 and SDS and other communicated information stipulated under JIS Z 7253. At JSR, we perform GHS-based hazard and toxicity classification and create appropriate labels, as well as provide SDS, for all of our domestic products that contain applicable substances. We will also strive to ensure our compliance with laws concerning this matter that are being enacted in other countries.

*6 Globally Harmonized System of Classification and Labeling of Chemicals

(3) Education on Chemical Substance Regulations

JSR provides in-house training on chemical substance regulations in Japan and abroad. In FY2020, we held domestic law seminars on new chemical substance registration and the amended Chemical Substances Control Act in Japan, and we held foreign law seminars on the substance registration systems used in China, Korea and Taiwan. These seminars were held at the head office and business establishments, and Group companies were also invited. A total of 71 people participated.

4. Response to Overseas Regulations Concerning Exported Chemicals, etc.

Countries around the world have been strengthening their chemical products laws and regulations in advance of 2020, as this was the target year for meeting an international goal^*7. Different countries have begun introducing new regulations, such as those requiring registration of existing chemical substances, following the EU’s enactment of the REACH Regulation in 2007, and JSR has been responding to each of these without omission in a manner that corresponds to business content and characteristics and local subsidiary systems. The legal and regulatory responses being undertaken by JSR for major production and import/export countries are detailed below; however, in addition to these, JSR is also ensuring compliance with the chemical product-related laws and regulations of numerous other countries, including those in ASEAN.

*7 WSSD 2020 Goal (long-term goal for chemical substances management that was adopted by the 2002 World Summit on Sustainable Development): Minimization of significant adverse effects on human health and the environment by 2020

(1) EU (REACH Regulation compliance)

The REACH^*8 Regulation was enacted by the EU in June 2007. Under REACH, all chemical products whose total production or import volume within the EU is one ton or more must register safety testing results and other data for the chemical substances contained in them, regardless of whether they are new or existing substances.
In order to ensure there is no disruption to our EU product production or import, we not only regularly check whether or not the substances JSR utilizes require registration, we also prepare for likely usage restrictions arising from future substance evaluations by sharing information with development departments and taking other steps to anticipate risk once evaluations commence.
In response to registration in Britain, which officially withdrew from the EU at the end of 2020, JSR has completed the necessary measures, such as designating the ‘Only Representative’ under UK REACH and preparing for the ‘grandfathering’ process.

*8 Registration, Evaluation, Authorisation and Restriction of Chemicals

(2) United States

In the United States, new chemical substance reporting is overseen by the Environmental Protection Agency under the Toxic Substances Control Act (TSCA) and other related federal laws and regulations. JSR follows all applicable legal procedures with regard to the manufacture and importation within the United States of substances not included on the list of existing chemical substances. Also, in response to the amended TSCA which went into effect in 2016, we work in conjunction with our local subsidiaries to flexibly respond to the new legal requirements, as well as promote responsiveness to regulatory trends accompanying the start of risk assessment.

(3) China

In China, reporting of new chemical substances is governed by the Measures for Environmental Management of New Chemical Substances, which was enacted in 2010. Since the establishment of this law, JSR has followed all applicable legal procedures with regard to the importation within China of substances not included on the “Inventory of Existing Chemical Substances in China.” An amended version of this law went into effect from January 2021, and we are working to ensure that there will not be any new chemical substance-related omissions in the future, as based on this amended law.

(4) Korea

In Korea, reporting of new chemical substances is governed by the Korean REACH^*9 Act and OSHA^*10 Act. JSR anticipates and follows all applicable legal procedures with regard to the manufacture and importation within Korea of substances not included on the list of existing chemical substances. The Korean REACH Act underwent major revisions in 2019, and, as a result, it is now required that existing chemical substances produced or imported within Korea in quantities of one ton or more must be registered. This pre-reporting in the preliminary stage was completed through coordination between JSR’s business departments and local subsidiaries. We will systematically support future registrations as well.

*9 Act on Registration and Evaluation of Chemical Substances

*10 Occupational Safety and Health Act

(5) Taiwan

In Taiwan, a registration system was introduced based on the Toxic Chemical Substances Control Act^*11 enacted in 2014. JSR follows all applicable legal procedures established in line with this new chemical substance registration system. Also, as part of efforts to update its existing chemical substances list, Taiwan has instituted “Existing Chemical Substance Nomination,” with the first designated target substances registration taking place in 2019. JSR’s compliance efforts have been primarily handled by our Taiwan subsidiary while working within a compliance framework appropriate to each business.

*11 (old) “Toxic Chemical Substances Control Act.” Amended in January 2019 to expand the scope of controlled chemical substances; the name was also changed to “Toxic and Concerned Chemical Substances Control Act” in order to reflect this expansion.

5. Chemical Management within Supply Chain Management

At JSR, we practice chemical management simultaneously with CSR procurement and green procurement/green purchasing as part of our supply chain management. In particular, from the standpoint of toxic chemicals management, we have introduced chemSHERPA as part of our green procurement practices, as it is the industry standard format for communicating toxic substances information, and this has helped ensure that we are able to smoothly and reliably relay information to suppliers and in-house handling departments, as well as to customers. Please refer to the following links for more information.

• CSR/Sustainable Procurement
• Green Procurement
• Green Purchasing

6. Industrial and International Measures

JSR is a member of the Japan Chemical Industry Association (JCIA) and contributes to its activities. JSR’s contribution includes participating in JCIA’s working groups, promoting activities of its Long-range Research Initiative (LRI)^*12 as a voluntary effort by the chemical industry, and providing a part of research funding.

*12 LRI (Long-range Research Initiative):
The Long-range Research Initiative (LRI) is a long-term, international initiative supporting research into chemical substances that have an impact on the environment, safety and health. It was begun as a voluntary global research grant program initiative of the International Council of Chemical Associations (ICCA), and it is currently being advanced through the cooperative efforts of the chemical industries associations of Japan, the United States, and the EU. In Japan, the Japan Chemical Industry Association (JCIA) is pursuing research into the following five topics: (1) development and evaluation of the new risk assessment method/development of methods for simple exposure evaluation and alternatives to using laboratory animals; (2) study on the safety of new chemical substances including nano materials; (3) study on the effects of chemical substances on children, the elderly, and gene disorders; (4) evaluation of the impact on ecosystems and the environment; and (5) other issues that require an emergency response.