Japan Japan Announces Plan to Add MCCPs and Long‑Chain PFCAs to CSCL List of Class I Specified Chemical Substances

Japan Announces Plan to Add MCCPs and Long‑Chain PFCAs to CSCL List of Class I Specified Chemical Substances

On February 2, 2026, Japan’s Ministry of Economy, Trade and Industry and other relevant ministries announced their intention to designate three groups of substances: chlorpyrifos; medium‑chain chlorinated paraffins (MCCPs); and long‑chain perfluorocarboxylic acids (long‑chain PFCAs), their salts, and long‑chain PFCA‑related substances as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL). This decision follows the twelfth meeting of the Conference of the Parties (COP12) to the Stockholm Convention, at which these three substance groups were newly listed for elimination.

 

Under this designation, no exemptions will be provided other than for testing and research purposes. As a result, the manufacture, import, and use of the targeted substances will, in principle, be fully prohibited. The prohibition may also extend to the “use” of these substances by businesses when manufacturing other chemicals or products. In addition, the import of certain products containing the targeted substances—such as wood preservatives, plasticizers for resins, commercial photographic film, and water‑repellent agents—is expected to be banned.

 

Points for Businesses to Note

Under the CSCL, no exemptions will be established for uses other than testing and research. Accordingly, a highly stringent measure will be introduced that prohibits the manufacture, import, and use of the targeted substances. The act of using a Class I Specified Chemical Substance to manufacture another chemical or product may also fall within the scope of “use” and therefore be prohibited.

However, if the item handled by a business is not considered a “chemical substance” but is instead treated as a “product” under CSCL administrative practice, regulations concerning the “use” of products do not apply.

 

Products Expected to Be Subject to Import Bans

For the three substance groups scheduled for addition, the following products that use these substances are expected to be prohibited from import.

 

 

Substance Products Expected to Be Subject to Import Ban
Chlorpyrifos • Wood preservatives
MCCPs • Plasticizers for resins

• Formulated additives used to impart flame‑retardant properties to fabrics, resins, or rubber

• Lubricating oils, cutting oils, and hydraulic oils

• Paints

• Adhesives and fillers for sealing

• Water‑repellent agents and textile protectants

Long‑chain PFCAs, their salts, and long‑chain PFCA‑related substances • Commercial photographic film

• Lubricating oils

• Paints

• Water‑repellent and oil‑repellent agents

• Adhesives and fillers for sealing

• Fire extinguishers, extinguishing agents for fire extinguishers, and foam extinguishing agents

• Waxes

• Fabrics treated to impart water‑repellent or oil‑repellent performance

• Clothing treated to impart water‑repellent or oil‑repellent performance

• Floor coverings treated to impart water‑repellent or oil‑repellent performance

 

Expected Timeline

  • From January 2026: Public comment period on the draft amended Cabinet Order
  • Around spring 2026: Promulgation of the amended Cabinet Order
  • From summer 2026: Promulgation of related ministerial ordinances
  • Around autumn 2026: Enforcement of the amended Cabinet Order and related ministerial ordinances

 

Related Links

“Designation of Substances Newly Listed for Elimination at the Twelfth Meeting of the Conference of the Parties to the Stockholm Convention as Class I Specified Chemical Substances under the Chemical Substances Control Law (Notice) (February 2, 2026)”:
https://www.meti.go.jp/policy/chemical_management/kasinhou/oshirase_260202.pdf

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