Reducing Use of Environmentally Harmful Substances
NSK’s Approach
In recent years, international regulations on chemical substances have been tightening, and companies are increasingly required to respond swiftly and appropriately to new legal requirements. The NSK Group regards thorough legal compliance as a foundation of its corporate activities, and is working to strengthen its ability to comply with laws and regulations both in and outside Japan.
As part of these efforts, the Group actively collects and analyzes the latest regulatory information — by participating in relevant seminars, regularly checking government gazettes, and consulting with relevant authorities — to obtain timely information on legal revisions, and shares it internally. In the European Union, a Digital Product Passport (DPP) framework for companies to manage and provide product information electronically is scheduled to begin implementation in 2026. This will require firms to adopt more advanced information management systems. In preparation for DPP implementation, the NSK Group is developing a way to systematically manage and provide accurate, comprehensive information on the chemical substances and materials contained in its products. By introducing a chemical substance management system and enhancing its information infrastructure, the Group will be able to centrally manage product chemical data, enabling efficient and reliable compliance with regulations while sharing information internally and externally.
Furthermore, based on the NSK List of Environmentally Harmful Substances, the Group rigorously manages and reduces chemical substance use at every stage, from development and design to procurement, production, and logistics. For environmental impacts from plant exhaust gases and wastewater, the Group has established its own voluntary standards that are stricter than legal requirements, and works diligently on environmental protection. It also requires suppliers to follow the NSK Group Green Procurement Standards and other guidelines, thereby promoting chemical substance management throughout the supply chain.
Looking ahead, the NSK Group will continue to respond accurately to international regulatory trends while aiming to balance product safety with environmental responsibility, contributing to sustainable manufacturing.
System
To reduce the environmental impact of the entire value chain, the NSK Group maintains a system for managing environmentally harmful substances. We develop rules for the management of environmentally harmful substances in accordance with laws, regulations, and industry standards related to the chemical substances that must be managed.
Management of Environmentally Harmful Substances
Targets and Performance
◆Mid-Term Management Plan 2026 (MTP2026) Targets, with Targets and Performance for Each Fiscal Year
| MTP2026 | FY2024 Targets | FY2024 Performance | Initiatives | FY2025 Targets | |
|---|---|---|---|---|---|
Development and design, procurement, and manufacturing | Full response to the 10 EU RoHS substances | Full response to EU RoHS (legal compliance) | Continued efforts to completely eliminate environmentally hazardous substances from developed products and manufacturing processes |
| Thoroughly manage by carrying out ongoing product content surveys and component analysis |
| Procurement | Conduct survey regarding inclusion of substances on the NSK List of Environmentally Harmful Substances | Conduct supplier audits of the management systems for environmentally harmful substances | Continued to conduct supplier audits and take corrective actions |
| Conduct supplier audits of the management systems for environmentally harmful substances |
Obtain responses from all target suppliers | Continued to obtain responses from all target suppliers |
| Obtain responses from all target suppliers | ||
| Manufacturing (Japan) | Handling of PRTR-designated substances per unit of sales: Continue to reduce by 1% year on year | Below -1% (base year FY2023) | -10.4% (base year FY2023) |
| Below -1% (base year FY2024) |
Initiatives
- 2006：Implemented product design and management in compliance with the EU RoHS Directive*1 and ELV Directive*2
- 2020：Implemented product design and management in compliance with the revised EU RoHS Directive*3 (including phthalates)
- 2022：Completed full elimination of materials containing PFOA in accordance with the EU REACH Regulation
- 2023：Started investigation and review for measures in response to regulatory trends on PFAS
- 2024：Started establishing a chemical substance information management system in preparation for the EU Digital Product Passport (DPP)
*1 RoHS Directive: An EU directive that restricts the use of six harmful substances in electric and electronic devices
*2 ELV Directive: An EU directive that prohibits the use of lead, mercury, cadmium, and hexavalent chromium in automotive parts and materials in order to promote the recycling of end of life vehicles
*3 Revised RoHS Directive: The revised RoHS Directive issued in 2014, now including phthalates and other substances added in 2019, restricts the use of 10 substances.
Green Procurement and Management of Environmentally Harmful Substances
The NSK Group believes that addressing increasingly serious global environmental issues requires initiatives not only within the group but throughout the entire supply chain, and the group actively promotes green procurement. Environmentally hazardous substances, identified independently based on laws and industry standards, are registered in the NSK List of Environmentally Harmful Substances.*1 The NSK Group Green Procurement Standards have also been established to ensure that parts, materials, lubricants, packaging materials, and other items containing or contaminated with prohibited substances are not delivered to plants. Based on these guidelines, suppliers are requested to maintain strict substance management and continuously improve their systems. Specifically, the Group strengthens collaboration with its business partners by obtaining their agreement to follow the NSK Group Green Procurement Standards, conducting regular surveys on environmentally harmful substances, auditing key suppliers, and promptly requesting corrective action if any issues are identified. In the FY2024 surveys and audits, no prohibited substances were found in parts or raw materials newly used in NSK products.
NSK products are supplied to global multinationals, and the final products in which they are incorporated — ranging from automobiles to electrical and electronic equipment — must comply with laws and regulations on environmentally hazardous substances in countries worldwide. To respond accurately to these regulatory trends, the Group updates the NSK List of Environmentally Harmful Substances each year. In FY2024, new regulated substances were added, mainly under the REACH Regulation,*2 to ensure thorough legal compliance. In addition, the NSK Group conducts annual surveys on environmentally harmful substances to strengthen collaboration with suppliers. This approach not only improves the accuracy of regulatory compliance but also establishes a system that can respond quickly and accurately to information requests from customers.
*1 A list classifying environmentally harmful substances as “prohibited” (substances that must not be included in or with delivered products), “reduced” (substances that will be reduced systematically), or “under observation” (substances whose inclusion must be monitored). In FY2024, new substances were added to the list, primarily under the REACH Regulation. The 2025 edition is currently being prepared, and in consideration of reducing the burden on suppliers and improving internal management efficiency, a transition is being considered from managing substances individually to managing them by regulatory framework.
*2 Regulation on the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) in the European Union
Provision of Product Safety and Chemical Substance Information
At NSK, we prepare and provide Safety Data Sheets (SDS) to ensure the safe use of our products. For certain products, we also publish SDSs on our website to enhance transparency and accessibility of information. In line with Japan’s revised Industrial Safety and Health Act that came into effect in April 2025, we updated the SDSs for applicable products ahead of enforcement and completed their provision to customers. Furthermore, to more clearly communicate information on safe use, such as recommended applications and required protective equipment, we are reviewing and updating the content of SDSs on an ongoing basis.
Compliance with the European RoHS Directive and Management of Harmful Substances in Manufacturing Processes
To ensure that the ten substances prohibited under the European RoHS Directive are not contained in its products, the NSK Group compiles lists of parts verified as free of these substances based on supplier survey results. These lists are used not only during product design verification but also when receiving parts at each plant, serving as part of our management system to prevent the unintentional inclusion of prohibited substances. The European RoHS Directive initially prohibited six substances, including cadmium, lead, mercury, and hexavalent chromium, with four types of phthalates added in July 2019. These phthalates are known to have migratory properties, meaning they can transfer to other materials upon contact, making them a particular concern for product safety. Accordingly, the NSK Group conducts global surveys not only on the materials and components of its products to ensure non-use, but also on contact materials used in manufacturing processes — such as resins, rubber gloves, and packaging materials. Through these efforts, we continue to eliminate the risk of phthalate migration during manufacturing and advance initiatives to maintain product quality and safety.
Management and Reduction of Substances Regulated under the PRTR Law
At its main production sites in Japan, the NSK Group is working to manage and reduce substances regulated under the PRTR Law.* We aim to reduce the volume per unit of sales of PRTR-designated substances handled by 1% each year compared to the previous fiscal year. In FY2024, by measures such as switching cleaning agents to Type 3 petroleum products, the volume handled per unit was reduced by 10.4% year on year. In manufacturing processes that use solvents, adhesives, and other materials containing volatile organic compounds (VOCs), we are promoting initiatives such as switching to low-VOC products and improving processes. In FY2024, the Group’s global VOC emissions amounted to 136 tons.
* Law concerning Pollutant Release and Transfer Register (PRTR): Act on Confirmation, etc., of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof. Japan’s law intended to facilitate improvement of chemical substance management by ensuring that amounts released into the environment are ascertained and reported to authorities.
Regulatory Compliance
When launching new products, chemical substance notification, registration, and volume reporting are required in accordance with various national regulations. The NSK Group ensures appropriate and reliable compliance with such regulatory requirements, including obligations to submit data on existing chemical substances under revised and newly enforced regulations worldwide. In responding to regulations outside Japan, we have continued to manage export volumes of chemical substances under the EU REACH Regulation and, after reviewing the regulatory requirements, have taken the necessary measures. In FY2024, the NSK Group had no violations of laws and regulations relating to chemical substance registration or notification. We are also preparing for the registration of existing chemical substances under South Korea’s K-REACH* law, and are steadily moving forward to meet the registration deadline of December 2027. Through these initiatives, the NSK Group is fulfilling its responsibilities not only for legal compliance but also for environmental protection and safety assurance, thereby contributing to the advancement of sustainable business activities.
* K-REACH (Act on the Registration and Evaluation of Chemical Substances): A regulatory framework in South Korea requiring phased registration of chemical substances manufactured or imported into the country, depending on annual import volumes.
Risk Assessment of Product Chemical Substances and Advancement of Supply Chain Management
To strengthen the risk assessment of chemical substances contained in its products, the NSK Group conducts assessments in compliance with key market regulations such as the EU REACH Regulation and K-REACH, using toxicological databases such as those of the European Chemicals Agency*1 and the U.S. Environmental Protection Agency.*2 In FY2024, we completed risk assessments for nearly 100% of products by sales volume, thereby promoting both product safety and environmental considerations. For supply chain management, we conduct annual supplier audits using a checklist from the Joint Article Management Promotion-consortium (JAMP) and share initiatives for chemical substance management through procurement policy briefings. These efforts help strengthen collaboration with suppliers and enhance information transparency. In addition, for chemical substances used in production processes, each NSK Group plant acquires and manages SDSs, and they record PRTR-designated substances and subject them to third-party verification, thereby ensuring both proper management of environmentally harmful substances and external reliability.
*1 The ECHA implements and enforces the EU REACH Regulation.
*2 The EPA conducts hazard assessments and regulates chemical substances in the United States.