Managing Chemical Substances

Managing Chemical Substances

Management of chemical substances is one of the key priorities for TOK from the perspective of social responsibility. In addition to compliance with all laws and regulations, group-wide efforts ensure the proper management of chemical substances in the supply chain while TOK remains mindful of globally expanding environmental issues. The Group defined its responsibility to local and international communities as one of the TOK Group Creeds that break down the management principles, and the Group has been working to reduce the impact on the environment by combating global warming, managing chemical substances, effectively using resources, and reducing waste, thereby gearing up the product stewardship activities for development of the semiconductor ecosystem as a material issue.

Major 2024 Initiatives and Future Key Measures

In order to ensure appropriate chemical substance management and reliable compliance with the environmental laws in each country, TOK introduced a chemical substance information management system in 2005, advancing collection and centralized management of substance information and legal information.

In 2022, the company introduced functions to rapidly determine legal compliance, and in 2024, TOK achieved automatic determination functions for shipping, strengthening its response capabilities and making its chemical substance investigations more efficient by expanding the system functions.

The company also established the TOK Group Standards on Chemical Substance Management to maintain and strengthen appropriate chemical substance information transmission systems by continuously updating and operating them in response to domestic and international legal revisions and customer requirements. Since 2023, TOK used Version 8 to strengthen information coordination with suppliers to achieve accurate and timely information provision to customers through safety data sheets (SDS) and labels.

Accurately Evaluated Chemical Substance Risks in a Timely Fashion and Properly Managed These Risks

The risk management of chemical substances can be interpreted as risk management of each part of the supply chain.

To this end, it is necessary for the TOK Group to provide information in accordance with the flow of materials. In each of the development, manufacturing, sales, and disposal stages, TOK creates and implements procedures for complying with all laws and regulations in order to manage all relevant risks.

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(1)  Obtaining information about revisions to laws, regulations, and treaties

For the chemical substances handled by the TOK Group, the company has a system for complying with legal requirements, ascertaining the use of regulated substances under the REACH regulation*1 and laws governing conflict minerals,*2 and determining whether or not such substances may be used. Moreover, for chemical substances that are likely to be banned from the future tightening of regulations, TOK formulates reduction plans for all products and manages the progress of such plans so that the company can stop using such sub stances before the laws come into force.

(2) Procurement stage

In addition to the SDS*3 for raw materials, TOK asks suppliers to submit the Warranty of Nonuse of Prohibited Substances to guarantee that the prohibited substances in the TOK Group Chemical Management Standards*4 are not contained in raw materials. TOK shares chemical substance information with suppliers based on these forms and pursues the correct identi fication of chemical substances contained in all raw materials.

(3) Development stage

For newly developed raw materials, in addition to the legal and regulatory information, TOK checks whether such raw materials contain chemical substances subject to the TOK Group Chemical Management Standards. Furthermore, the company performs similar checks for customer requirements for newly developed products and formulates a substitution plan in the event the specified standard is exceeded.

(4) Production stage

All raw materials used in the manufacture of products are subject to occupational health and safety risk assessments. TOK identifies hazardous factors in the production environment, clarifies the hazard level, implements measures to mitigate and eliminate the hazardous factors based on that risk level, and takes action to lower all risks. In this way, TOK maintains the proper work environment for all personnel.

(5) Marketing stage

By linking the ERP system for managing product shipment volumes and the chemical substance management system that contains product composition data, the company automatically calculates the transfer volume of chemical substances, reports the proper volumes, and requests their application in accor dance with the Chemical Substances Control Act*5 and the PRTR Act*6 of Japan and with all environmental laws and regu lations of importing countries. The company also enabled the issuance of SDS documents in accordance with current local laws and regulations using the SDS preparation system so that proper safety information will be shared with all users.

(6) Disposal stage

Waste from each site is thoroughly sorted by type and recycled and properly disposed of when necessary. For the contracted industrial waste disposal service providers, TOK provides information about the type of waste and handling precautions through waste data sheets (WDS). The company periodically visits service providers for on-site audits to ensure that all waste is being properly disposed of in accordance with the contractual agreements.

*1 REACH regulation: Registration, Evaluation, Authorization and Restriction of Chemicals; This EU regulation manages the registration, evaluation, and accredi tation of chemical substances through an integrated system with the aim of ensuring complete fulfillment of responsibility on the producers’ part as well as thorough compliance with preventive principles.

*2 Conflict minerals: Four minerals (tin, tantalum, tungsten, and gold) produced in the Democratic Republic of the Congo and surrounding conflict zones; These minerals are regulated under the U.S. Dodd-Frank Act (financial regulation reform act). From the perspective of responsible mineral procurement, the TOK Group includes cobalt and mica in the scope of investigations in addition to the four minerals above.

*3 SDS: Safety Data Sheet

*4 TOK Group Chemical Management Standards: Clarifies chemical substances to be managed in order to respond to international laws and regulations and customer requirements

*5 Chemical Substances Control Act: Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture (Japan)

*6 PRTR Act: Act on Confirmation of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof (Japan)

 

TOPICS

Initiatives in Response to Global Environmental Regulations

In 2022, PFHxS was newly added to Annex A (global ban) of the POPs Convention. The overall regulation of PFAS was also considered under the EU REACH Regulation and the United States TSCA. In this way, global regulation of persistent and highly accumulative chemical substances has proceeded in recent years.

In Japan, major chemical substance management regulations have been revised one after another, such as the Industrial Safety and Health Act (addition of PFHxS and its salts as Class I Specified Chemical Substances) and the PRTR Act. TOK personnel need to properly disclose the information on the safety of chemical substances contained in all chemical products to customers and employees and to properly develop and manufacture beneficial chemical products while taking environmental considerations into account.

In particular, the PFAS restriction proposed by the EU in 2023 is targeted at a wide range of chemical substances and will affect TOK and other chemical manufacturers as well as a broad range of industries engaged in equipment, containers, and packaging materials.

TOK complies with the regula tions and proactively provides information concerning safe handling through communication with industrial associations and regulatory authorities in order to minimize the impact of environmental regulations on production.

Participation in chemSHERPA

In July 2017, TOK adopted the chemSHERPA information transfer schemes for chemical substances contained in products. Initially proposed by the Ministry of Economy, Trade and Industry, chemSHERPA was established with agreements of some electronics-related companies. The scheme aims to create a common format for accurately and efficiently conveying information about chemical substances contained in products from upstream to downstream operations. As the organization that manages chemSHERPA, JAMP*1 counts 539 companies*2 (including TOK) as members. Through this organization, TOK obtains the latest information about chemical substances and broader trends, which is used to further improve its management of chemical substances.

*1 Joint Article Management Promotion-consortium
*2 As of Semtember 16, 2025

Responsible mineral procurement

We promotes responsible mineral procurement throughout the supply chain based on the spirit of coexistence and co-prosperity with our business partners, as well as laws, regulations and social norms. 

CSR Procurement Policy

 

Future Issues and Initiatives

In the understanding of chemical substances management, a shift from hazard management to risk management is indispensable. TOK regards the enhancement and use of risk assessment as a key requirement. TOK also considers that the communication of risk information through supply chain leads to the matured chemical substances management throughout the entire supply chain in all industries. Under the concept of the material issue of supply chain sustainability, the Company strives to establish a system for the timely and proper communication of risk information.

Related Material Issue