The Environment Ministry opened public comment on 4 November on a revised draft of the basic policy under Japan's Green Purchasing Law, which sets the products national government bodies and independent administrative agencies are expected to buy first. Comments are accepted until 3 December; the e-Gov listing puts the cutoff at 0:00 on 4 December.
The consultation is voluntary rather than a procedure required under the Administrative Procedure Act, and it rests on Article 6(6) of the law.
A steel test for the top tier
The draft's common criteria apply to any item made with steel. Under them, the higher tier (criterion 1) requires steel whose emissions-reduction credit is reflected in the product and whose lifecycle greenhouse-gas emissions are disclosed as a quantified figure. The credit must be calculated under the Japan Iron and Steel Federation's GX Steel Guideline.
The draft carves out cases where the time a manufacturer makes a product that meets criterion 1 differs from the time that product is sold, making steel that meets the criterion difficult to use. In those cases the steel requirement does not apply. It also lists two "consideration" items that are not requirements: steel made with non-fossil electricity, and clearance metal. The draft defines clearance metal as metal used at nuclear facilities that is treated as not contaminated by nuclear fuel material after confirmation by Japan's nuclear regulator, and it includes metal given an equivalent confirmation abroad.
The draft ties the review to Japan's green transformation push. It cites a February 2025 cabinet-approved strategy that calls public-sector purchases of advanced green products important for creating early demand.
How the tiers work
Where an item has two tiers, each agency sets a quantitative annual target for both criterion 1 and criterion 2, and is to buy at criterion 1 unless supply constraints or other obstacles prevent it. Such an item reaches criterion 1 by meeting its own criterion 1, or by meeting the common criterion 1 together with its criterion 2. An item that misses the common steel criterion can still qualify at criterion 2 if it meets the item-specific standard.
Grace periods in the draft
Several phase-ins appear in the item-level standards.
- Refrigerators and freezers: products that meet the energy-efficiency criteria in the policy approved by cabinet on 3 February 2026 are deemed to meet the corresponding energy criteria until 30 September 2027.
- Passenger cars: the air-conditioner refrigerant requirement does not apply until 31 March 2027.
- Recycled-plastic requirements for magnetic disk drives, displays and refrigerators: a one-year grace period in the fiscal year starting April 2027.
The draft PDF prints struck and inserted text together, so changed lines are hard to isolate from the text alone.
How to comment
Submissions go through the e-Gov comment form or by email to the ministry's economy division ([email protected]), in the body of the message with no attachments. They must be in Japanese and no longer than 2,000 characters, and must give the page and line of the draft they address. Hand delivery and phone comments are not accepted, and the ministry will not reply to individual submissions. Comments may be published, except for contact details.