This Letter Cordially Asks Your Government to Provide Us with Information on Nine Chemicals

Preface

Background

This letter cordially asks your government to provide us with information on nine chemicals which will be newly regulated in Japan.

The Japanese Government is now scrutinizing domestic regulations in order to respond to the addition of nine chemicals to the annexes of the Stockholm Conventionon Persistent Organic Pollutants, which was adopted at its fourth meeting of the Conference of the Parties in May 2009.

In order to protect human health andno allowed (see tables above)or living organisms from hazardous chemicals released to the environment, Japan has implemented a strict chemical safety policy based on the “Act on the Evaluation of Chemical Substances and Regulation of their Manufacture, etc.(the Act)”. The Act restricts production, import and the use of “Class I Specified Chemical Substances”, which are prescribed by the Cabinet Order and defined as follows: a chemical which is (a) persistent, (b) bio-accumulative, and (c) hazardous to human health or the life andno allowed (see tables above)or growth of top predators when ingested continuously.

The Act also restricts import of products containing those chemicals, and those restricted products are prescribed by the Cabinet Order as well. Currently, sixteen chemical substances, including ten chemical substances listed on the Annex A and B of the Stockholm Convention, are prescribed as “Class I Specified” chemicals by the Cabinet Order. This time, the nine new chemical substances which will be added to the annexes of the Conventionshould accordingly be prescribed as such.

Under the Article 13 of the Act, the Cabinet Order for import restriction of products shall be established with consideration of matters relating to the conditions of use, etc., of the “Class I Specified Chemical Substance” in foreign countries. For that purpose, it is essential for us to grasp the production and import volume of the chemical and also the import volume of products containing the chemical in foreign countries. Whenever we prescribe “Class I Specified” chemicals, we have conducted a comprehensive international survey on those chemicals and the products containing those chemicals. With kind cooperation of foreign governments, our list of products prescribed by the Cabinet Order successfully covers all kinds of products containing chemicals currentlyclassified as “Class I Specified”. Once again, we would like to ask your government to cooperate to such a surveyon the nine candidates of “Class I Specified” chemicals.

We truly appreciate your government’s assistance and cooperation and express our gratitude in advance.

Filling out the Questionnaire

Please fill out the questionnaire attached below. When completing this form, please put as much information as necessary. If you would like to submit additional information to expand or clarify your responses, please feel free to do so.

Definitions

“product”：does not only refer to “primary products”, which are produced by using the listed chemical, but also includes “secondary products” etc., which are processed after the production.

QUESTIONNAIRE [I]

Please fill out the information about your country’s contact point.

Contact Point

Country

Contact Person

QUESTIONNAIRE [II]

This questionnaire relates tofollowing 9 chemicals andtheirproducts containing them.

Lindane (Gamma HCH or Gamma hexachlorocyclohexane)

Alpha hexachlorocyclohexane(Alpha HCH)

Beta hexachlorocyclohexane(Beta HCH)

Tetrabromodiphenyl ether and pentabromodiphenyl ether (2,2',4,4'-tetrabromodiphenyl ether (BDE-47) and 2,2',4,4',5-pentabromodiphenyl ether (BDE-99) and other tetra- and pentabromodiphenyl ethers present in commercial pentabromodiphenyl ether.)

Hexabromodiphenyl ether and heptabromodiphenyl ether (2,2',4,4',5,5'-hexabromodiphenyl ether (BDE-153), 2,2',4,4',5,6'-hexabromodiphenyl ether (BDE-154), 2,2',3,3',4,5',6 heptabromodiphenyl ether (BDE-175), 2,2',3,4,4',5',6-heptabromodiphenyl ether (BDE-183) and other hexa- and heptabromodiphenyl ethers present in commercial octabromodiphenyl ether)

Chlordecone

Hexabromobiphenyl

Pentachlorobenzene

Perfluorooctane sulfonic acid,its salts and perfluorooctane sulfonylfluoride

II-A Regulation of the chemicals on production, import and use

1. Are production, import andno allowed (see tables above)or use of the chemicals listed below allowed in your country?

※”Use” means to incorporate or mix the chemical into some products.

1. Please summarize the regulation(s) and scientific knowledge which the regulation(s) are based on.

II-B Amount ofthe chemical on production and export

1. What are the production volumes of the chemicals listing below? (year 1999-2008)

2. What are the export volumes of the chemicals listed belowto each country respectively? (year 1999-2008)

3. What are the volumes of the use of chemicals listed below? (year 1999-2008)

II-CRegulation of products containing the chemicals on production, import and use

1. Are production, import andno allowed (see tables above)or use of products which contain the chemicals listed below allowed in your country?

※.”Use” means to use products which contain the chemicals here.

2. Please summarize the regulation(s) and scientific knowledge which the regulation(s) are based on.

II-DContent in the product,amount of products on production and export

*Notice:

Perfluorooctane sulfonicacid (PFOS), its salts and perfluorooctane sulfonylfluoride(PFOSF) are added to the list of the Annex B of the Convention on Persistent Organic Pollutants with acceptable purposes and specific exemptions.Somecountries, such as China and India, have required continuous use of these substances forproducts, such ascarpets, leather, apparel, textile, upholstery, paper and packaging, rubber, plastics, insect baits for control of leaf cutting ants, and insecticides for control of red imported fire ant and termites. Thus,it is desirable to describe products containing PFOS, its salts and PFOSF in detail as possible for the purpose of this questionnaire, like ‘filler with silicon rubber system for sealing’ and ‘adhesive agent for electric and electronic parts’, because these information needs to determine target products for regulation.

1. Please describe the average contents of the chemical in products and their production volume.(year 1999-2008)

2. Please describe export volumes of the product using the chemicals below to each product respectively. (year 1999-2008)