Chemical Regulations for Surface Treatment Sites — Toxic Substance Concentration Criteria, Business Licensing and Handling Standards, and Emission Surveys (PRTR) under the Chemicals Control Act
Sulfuric acid, sodium hydroxide, nitric acid and other chemicals used at anodizing sites are toxic substances under the Chemicals Control Act above certain concentrations. This article summarizes, based on confirmed provisions, the concentration criteria in the Designation of Toxic Substances notice, hazardous chemical business licensing and handling standards, and the chemical emission survey system.
Anodizing and chemical conversion coating processes routinely handle acids, alkalis and metal salts. Depending on concentration, these chemicals are hazardous chemicals under the Chemicals Control Act, which brings obligations for business licensing, handling standards, handling facility inspections and emission surveys. This article covers the scope confirmed in published laws and notices.
Concentration Criteria in the Designation of Toxic Substances
Toxic substances are listed with substance-specific concentration criteria in the Designation of Toxic Substances (National Institute of Chemical Safety Notice No. 2025-2, amended 2025-01-24, effective 2025-04-25). The criteria for substances commonly used in surface treatment are as follows.
| Substance (ID No.) | Toxic substance criterion |
|---|---|
| Sulfuric acid (97-1-405) | Sulfuric acid and mixtures containing 10 % or more |
| Fuming sulfuric acid (97-1-96) | Mixtures containing 10 % or more |
| Sodium hydroxide (97-1-136) | Mixtures containing 5 % or more |
| Potassium hydroxide (97-1-137) | Mixtures containing 5 % or more |
| Nitric acid (97-1-246) | Mixtures containing 10 % or more |
| Hydrogen fluoride (97-1-382) | Mixtures containing 1 % or more |
| Ammonium bifluoride (97-1-237) | Mixtures containing 1 % or more |
| Chromic anhydride (97-1-94) / Chromic acid and its salts (97-1-271) | Mixtures containing 0.1 % or more |
| Nickel oxide and nickel sulfides (97-1-130) | Mixtures containing 0.1 % or more |
Diluted rinse water and low-concentration chemicals below the criteria are not toxic substances, but concentrates and process-strength electrolytes, etching solutions and desmutting solutions mostly exceed the criteria. Some substances, such as sulfuric acid, may also be designated as accident preparedness substances, so this should be checked separately.
Business Licensing and Handling Standards
- Article 28 (Business License for Hazardous Chemicals): Among those intending to conduct hazardous chemical business, persons required to submit a chemical accident prevention and management plan must submit a license application for each site in advance, together with a chemical accident prevention and management plan that has received a notice of conformity under Article 23(5) and a handling facility inspection report found conforming under Article 24(6). Paragraph 6 provides a reporting procedure in place of a license for business operators meeting certain requirements.
- Article 13 (Handling Standards for Hazardous Chemicals): Requires that handling facilities be maintained to perform as designed, that safety accident prevention measures and emergency response for chemical accidents be in place, that different types of hazardous chemicals not be stored together, that container performance be maintained, that care be taken during loading, unloading and transfer, and that transport personnel be qualified. Detailed standards are set out in the annexes to the Enforcement Rule.
Chemical Emission Survey (PRTR)
Under Article 11 of the Chemicals Control Act, Article 5 of its Enforcement Rule and the Regulation on Chemical Emission Surveys and Calculation Factors (Ministry of Environment Notice No. 2014-255), sites in covered industries that hold emission facility permits or reports under the Clean Air Conservation Act or the Water Environment Conservation Act must survey and report environmental releases and transfers of the surveyed chemicals. According to local government guidance, the survey covers Group I substances (20) handled at 1 ton or more per year and Group II substances (395) handled at 10 tons or more per year, and the calculation covers not only raw materials manufactured or used but also process auxiliaries, stored substances and chemicals in waste. Survey results are published through the Chemical Release and Transfer Information Disclosure System.
Practical Checklist for Surface Treatment Sites
- Confirm concentrations from the MSDS of each chemical handled and list whether each is a toxic substance or accident preparedness substance
- Periodically confirm that the scope of the business license (or report) matches the substances and quantities actually handled
- Manage the periodic inspection cycle of handling facilities and the grounds for changes to the chemical accident prevention and management plan
- Maintain a system for tallying annual quantities of substances subject to the emission survey
EF Technology reviews its obligations under the Chemicals Control Act according to the concentration criteria of the chemicals it handles and fulfills the related licensing, inspection and survey requirements.
References
- Designation of Toxic Substances (National Institute of Chemical Safety Notice No. 2025-2, effective 2025-04-25), full text
- Chemicals Control Act, Article 28 (Business License for Hazardous Chemicals)
- Chemicals Control Act, Article 13 (Handling Standards for Hazardous Chemicals)
- Chemical Release and Transfer Information Disclosure System, legal basis for the emission survey
- Goyang Special City, guide to the chemical emission survey
- Enforcement Rule of the Water Environment Conservation Act, Annex 4: Wastewater Discharge Facilities