Category Archives: Chemical pollution

School “Artificial Turf” Chemical Problem

Open Letter of Inquiry on Artificial Turf


20 March 2023

Tokyo Metropolitan Government, Office of Education

To: Kayoko Hama, Superintendent of Education

Consumers Union of Japan (CUJ)

Co-Chairperson: Azuchi Kameyama

Co-Chairperson Miyoko Sasaki

Co-Chairman Martin Frid

Open letter of inquiry regarding artificial turf

We are a consumer organization working for safe and secure living.

We understand that the Tokyo Metropolitan Government is “promoting the turfing of schoolyards and other areas in all public elementary and junior high schools in Tokyo to further enhance the educational environment,” and recently we often see schoolyards with artificial turf instead of natural grass. However, in recent years, plastic pollution has become increasingly serious, and efforts to reduce the use of plastic are being made around the world. Artificial turf, in particular, is the most common microplastic found in rivers.

Professor Hiroshi Okochi of Waseda University has pointed out that artificial turf may also contribute to microplastic pollution in the atmosphere.

Therefore, we would like to ask the following questions, and would appreciate it if you could answer them by April 20. Your answers will be posted on the organization’s website.

Please explain in detail the main purpose of the schoolyard turfing project. Do you think artificial turf is effective in achieving these objectives? For example, do you think that artificial turf is not appropriate as a place for children to connect with nature?

CUJ heard that the schoolyard turfing project was originally part of the “Green Tokyo 10 Year Project” and was intended to counteract the heat island effect. Will artificial turf work as a heat island countermeasure?

Artificial turf will eventually deteriorate and will need to be replaced. The artificial turf cannot be burned or recycled as it is, and most of it is land filled at final disposal sites. What is the Tokyo Metropolitan Government’s policy on the disposal of artificial turf?

The Tokyo Metropolitan Government subsidizes the cost of turfing school grounds. If artificial turf is to be installed, will it be subsidized as well? We think it needs to be reviewed.

The Tokyo Shimbun (1 July 2021) reported: According to the Tokyo Metropolitan Office of Education, artificial turf schoolyards are used in approximately 120 ward elementary schools in 23 wards, and in Adachi Ward, 28 of 69 ward elementary schools have adopted artificial turf.

How many of Tokyo’s 23 wards’ public elementary and junior high schools currently have artificial turf and how many have natural turf? If possible, please tell us by ward. We would also appreciate it if you could tell us the situation of elementary and junior high schools in Tokyo other than those in the 23 wards.

Japan Resources – 187

Please click here for our latest English newsletter (pdf)JR 187


From the Editors: It Is All Connected

Report on the Special Forum for the Promotion of Organic School Lunch all over Japan

Growing Movement to Prevent Distribution of Genome-Edited Tomato Seedlings to Elementary Schools and Welfare Facilities

Public Comment: Ban 30 Substances in Pesticides

Press Release: “We Decide What We Eat Ourselves”

In the News: Over 11 years, close to 9 million people sign drive against nuclear power

From the Editors: It Is All Connected

This year ends with COP15 of the UN conference for biological diversity. We hope media will follow it as much as they did the recent COP27 of the UN conference for climate change.

In fact, these two global issues are interconnected and linked in many ways, that also influence us as consumers (and we, as consumers, can – and should – influence).

For example, by increasing the local and organically farmed food served to school children, Japan could go a long way to contribute to both mitigate climate change and protect biodiversity.

Some 3600 people all over the country are ready to make it happen, according to Koa Tasaka’s report from the Special Forum held in Tokyo this fall.

Please stay updated with CUJ’s activities and news on our English website, as well as on our English Twitter account:



Public Comment: Ban 30 Substances in Pesticides

Pesticides used in agriculture can contain many ingredients that are not well known and may be unsafe to humans and the environment. 
Proposed Ministerial Order to Prohibit 30 Substances of in Pesticides

Mr. Tetsuro Nomura, Minister of Agriculture, Forestry and Fisheries

To: Agricultural Safety Management Division, Consumption and Safety Bureau, Ministry of Agriculture, Forestry and Fisheries

20 October 2022

From: Consumers Union of Japan (CUJ)

Co-Chairperson: Ado Kameyama

Co-Chairperson Miyoko Sasaki

Co-Chairperson Martin Frid

Regarding the Proposed Ministerial Ordinance to list and ban the use of 30 auxiliary ingredients of agricultural chemicals in the Standards for Refusal of Registration under the Agricultural Chemicals Control Law:

We, Consumers Union of Japan, are a consumer organization working for the safety of food and agriculture, and the safety and security of our daily lives. We believe that there are several problems with the Ministerial Ordinance to Provide for Cases Specified by Ordinance of the Ministry of Agriculture, Forestry and Fisheries and the Ministry of the Environment under Article 4, Paragraph 1, Item 11 of the Pesticide Control Act (12 October 2022), which was presented by the Ministry and for which public comments were solicited.

We hereby petition for reconsideration and improvement as follows:

1. Proposal to Include 30 Auxiliary Ingredients of Agricultural Chemicals in the Criteria for Refusal of Registration

(1) CUJ is opposed to the proposal to include 30 auxiliary ingredients of pesticides in the Criteria for Refusal of Registration if they account for 0.1% or more of the total weight of the pesticide. We demand that none of them shall be detected and that their use in small quantities also be prohibited.

(2) CUJ opposes the enforcement date of 1 October 2025. If the law comes into effect three years later, some of the pesticides (preparations) currently on the market will contain these 30 auxiliary substances, and they will still be on the market. This could lead to a “rush to market” by manufacturers and distributors, and the continued use of pesticides even though it is known that they contain toxic auxiliary ingredients. The ministerial ordinance should be enforced immediately after its enactment.

(3) In addition to including these 30 auxiliary ingredients in the Standards for Refusal of Registration, we demand that the Standards for Refusal of Registration be applied to pesticides containing these ingredients that are currently being sold and used, and that all pesticides containing these 30 substances be promptly suspended or prohibited from use. This should result in their immediate recall from the market, and the cessation of their use, including in farmers’ inventories. It is unacceptable for pesticides containing toxic auxiliary ingredients to continue to be released into fields and the environment (It is well known that pesticides cause air pollution, soil contamination, and pollution of rivers, lakes, marshes, and the sea). A total ban on the use of pesticides (preparations) containing these auxiliary ingredients themselves should be promptly adopted.

(4) CUJ is opposed to the transitional measures that will allow registration until the enforcement date, that will allow the registration of pesticides using these banned auxiliary ingredients, as well as their sale and use until their expiration date (generally said to be 5 years). Under the five-year grace period, pesticides containing 30 carcinogenic and other toxic ingredients will continue to be sold and used for almost five years. It cannot be denied that these 30 auxiliary ingredients are carcinogenic, chronically toxic, and having toxic effects known as endocrine disrupters or environmental hormones even at trace amount levels. They should be enforced immediately without transitional measures.

(5) CUJ demands that the trade names of the pesticides (formulations) currently on the market (including farmer-retained products) that use the 30 auxiliary ingredients be listed and made public immediately. The current labeling on pesticide containers and packaging only lists type and amount of auxiliary ingredients. With descriptions such as “surfactant” or “emulsion” as the type, it is not possible to determine whether these 30 toxic chemicals are included or not. The “right to know”, “right to choose”, and “right to be safe” of users, consumers, and citizens who may be exposed to pesticides when using them, such as farmers, users in non-farming areas, home gardeners, and residents living near areas where pesticides are sprayed, should be ensured.

(6) CUJ demands that all applicable pesticides (formulations) be required to display a warning label with product names.

(7) CUJ demands that administrative guidance to encourage the recall and suspension of the use of these products be thoroughly strengthened as mentioned above.

2. Future Criteria for the Refusal of Registration and Review of Agricultural Chemicals

(1) The 30 auxiliary ingredients of pesticides proposed this time are substances with extremely high toxicity, such as carcinogenic substances, which will be included in the Standards for Refusal of Registration based on scientific data, and their use will be prohibited. We request that the toxicity of auxiliary ingredients other than the 30 substances be promptly investigated and that substances with relatively high or moderate toxicity be promptly included in the Criteria for Refusal of Registration.

(2) In the Materials to be submitted in applications for registration of agricultural chemicals (17 August 2021), the materials to be submitted as Test Results on Effects on Humans are still mainly related to active ingredients of the pesticide ingredients, and the overall toxicity of the pesticide (preparation) is not included. Thus the overall toxicity of the pesticide (formulation) is limited to acute toxicity. Test results for auxiliary ingredients are not required to be submitted. In the future, we request that test results on chronic toxicity, carcinogenicity, neurotoxicity, developmental neurotoxicity, etc. of pesticides (preparations) be included in the submission materials, paying attention to the toxicity of auxiliary ingredients as well.

(3) We should not use chemicals that require gas masks in the cultivation process of producing food. On the other hand, with regard to many pesticides, such as neonicotinoid pesticides and organophosphorous pesticides, for which there is already scientific evidence showing health effects and a ban on their use has been suggested, the precautionary principle should be proactively adopted. CUJ is of the opinion that highly hazardous pesticides and substances that may be endocrine disrupters should be promptly banned.

Original post (in Japanese):


Kick the Pesticide Industry Out of FAO!

Consumers Union of Japan is one of the 430 civil society and indigenous peoples organizations from 69 countries who signed the letter to the FAO Council to end the agency’s partnership with the pesticide industry (CropLife International)! Pesticide Action Network is submitting the letter to the FAO Council in Rome, Italy today, 9 June 2022.

Letter (pdf) here: English-CSO-and-IP-Letter-to-FAO-Council-RE-Ending-CLI-Partnership


Japan Resources – 185

Please click here for our latest English newsletter: JR 185

From the Editors: Growing Movement

Exposing Fragrance Pollution in Japan

Violating Consumers’ Right to Know and Choose

Essay: Unexpectedly…

From the Editors: Growing Movement

Welcome to issue No. 185 of Consumers Union of Japan’s English newsletter. The theme of this issue is “Exposing Fragrance Pollution in Japan” where we discuss the problem and the growing movement trying to deal with it. CUJ and other organisations have been acting as a principal driver of the movement for the last several years.

We also have an update on the Japanese government’s assault on consumers’ right to know and choose, as it moves to make certain popular, and useful, food labels illegal, including GMO-free labels.

We hope you will stay updated with CUJ’s activities and news on our English website, as well as on our English Twitter account: