Japan Japan Convenes Council to Discuss Regulatory Measures for PFHxS-Related Substances

Japan Draft PFAS POPs Chemical Substances (Products) Industrial Chemicals
29 August 2025  AOKI Kenji  AOKI Kenji (EnviX, Ltd.)

On July 22, 2025, Japan held a joint council meeting among the Ministry of Health, Labour and Welfare (MHLW), the Ministry of Economy, Trade and Industry (METI), and the Ministry of the Environment (MOE) to discuss the handling of PFHxS-related substances, which were deemed appropriate for designation as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL). The meeting addressed the following three agenda items:

  • Agenda Item 1: Handling of PFHxS-Related Substances
    Discussions focused on regulatory approaches to manufacturing and import, management of products containing these substances, and potential import bans.
  • Agenda Item 2: Future Measures for Essential Uses of 8:2 Fluorotelomer Alcohol
    As the substance no longer meets the CSCL Article 25 criterion of “difficulty in substitution by other substances,” the council concluded that its designation for essential use should be revoked.
  • Agenda Item 3: Evaluation of Biodegradability of Priority Assessment Chemical Substances Using Weight of Evidence
    Two substances (serial numbers 281 and 282) were determined to be readily biodegradable and will undergo screening and risk assessments.

 

Details of Agenda Item 1: Handling of PFHxS-Related Substances

The council deliberated on the following: products subject to import bans, essential uses to be designated by Cabinet Order, and products required to comply with technical standards specified by Cabinet Order.

Regulatory Measures for Manufacturing and Import

PFHxS-related substances are not exempted for specific uses under the Stockholm Convention and have no record of domestic manufacture or import in Japan. Therefore, the council deemed it appropriate to prohibit their manufacture, import, and use under the CSCL, except for research and testing purposes.

Management of Products Containing PFHxS-Related Substances

Foam fire extinguishing agents suspected to contain PFHxS-related substances were confirmed to exist in domestic inventories. Accordingly, the following products, if containing PFHxS-related substances, should be designated by Cabinet Order as subject to technical standards and labeling requirements to prevent environmental pollution:

  • Fire extinguishers, extinguishing agents, and foam extinguishing agents (product classifications subject to future revision):
    • Fire extinguishers (HS Code 8424)
    • Extinguishing agents and foam extinguishing agents (HS Code 3813)

Import Ban on Products Containing PFHxS-Related Substances

Following investigations into domestic usage and import trends of PFHxS-related substances, the following product categories have been identified as subject to import bans when such substances are present:

  • Fire extinguishers, extinguishing agents, and foam extinguishing agents
  • Etching agents for metal processing
  • Surface treatment agents and additives for plating
  • Treated fabrics with water- or oil-repellent properties
  • Treated garments with water- or oil-repellent properties
  • Treated floor coverings with water- or oil-repellent properties
  • Water- and oil-repellent agents and textile protectants
  • Anti-reflective coatings used in semiconductor manufacturing
  • Etching agents used in semiconductor manufacturing
  • Photoresists for semiconductor applications

Note: Product classifications and terminology may be revised as necessary, contingent upon confirmation of relevant management systems

 

Future Schedule for PFHxS-Related Substances

To formally designate PFHxS-related substances as Class I Specified Chemical Substances and implement necessary measures, the following schedule is planned:

From September 2025

Notification under the WTO Technical Barriers to Trade (TBT) Agreement and public comment on the draft Cabinet Order amending the CSCL Enforcement Order.

From 2026 onward

    • Further deliberations in the three-ministry joint council on designation of PFHxS-related substances
    • Promulgation of revised Cabinet Order and Ministerial Ordinance for designation
    • Enforcement of revised Cabinet Order and Ministerial Ordinance

 

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Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting

Background

MSc in Earth Science, The University of Tokyo

AOKI Kenji