Japan Government Promulgates Amended Enforcement Order Designating Long‑Chain PFCAs, etc as Class I Specified Chemical Substances under the CSCL 
In Japan, the Ministry of Economy, Trade and Industry (METI); the Ministry of Health, Labour and Welfare (MHLW); and the Ministry of the Environment (MoE) promulgated “the Cabinet Order Partially Amending the Enforcement Order of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Cabinet Order No. 171)” in the May 22, 2026, issue of the Official Gazette. Under this Cabinet Order, “perfluoroalkanoic acids (limited to those with carbon numbers from 9 to 21; long‑chain perfluoroalkanoic acids; hereinafter, ‘long‑chain PFCAs’) or their salts,” “long‑chain PFCA‑related substances,” “chlorpyrifos,” and “medium‑chain chlorinated paraffins (hereinafter, ‘MCCP’)” are newly designated as Class I Specified Chemical Substances under the CSCL, and their manufacture, import, and use are prohibited. As a result, certain products containing these substances—such as lubricants, paints, and wood preservatives—will be prohibited from import. In addition, fire extinguishers, fire‑extinguishing agents for fire extinguishers, and foam fire‑extinguishing agents that contain long‑chain PFCAs, etc will, for the time being, be newly subject to technical standards for handling and labeling requirements. This Cabinet Order will enter into force on November 22, 2026.
Background and Overview of the Cabinet Order
This Cabinet Order constitutes Japan’s domestic implementation measures following the decision adopted at the twelfth meeting of the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants, held from April 28 to May 9, 2025, to newly add the four substances listed above to “Annex A (Elimination).”
The main amendments introduced by this Cabinet Order are as follows.
Additional Designations as Class I Specified Chemical Substances
Four types of substances, listed in the table below, are added to Article 1 (“Class I Specified Chemical Substances”) of the Enforcement Order.
| Order No. | Class I Specified Chemical Substance | Overview of Definition and Scope |
|---|---|---|
| 41 | Long‑chain PFCAs or their salts | Carbon numbers from 9 to 21 |
| 42 | Long‑chain PFCA‑related substances | Compounds that contain a perfluoroalkyl group (limited to those with carbon numbers from 8 to 20) directly bonded to atoms other than fluorine, chlorine, or bromine, and that are designated by the Ministerial Ordinance as substances that generate long‑chain PFCAs through chemical transformation by natural processes (excluding perfluorooctanoic acid‑related substances) |
| 43 | Chlorpyrifos | — |
| 44 | MCCP | Carbon numbers from 14 to 17 with chlorine content of 45 percent or more by molecular weight |
The specific group of substances classified as “LC‑PFCA‑related substances” is scheduled to be defined by ministerial ordinances after a public consultation process conducted through a joint three‑ministry council, and in alignment with the full enforcement of the Cabinet Order in the autumn of 2026.
Additional Designations of Products Prohibited from Import
Following the additional designations as Class I Specified Chemical Substances, the products listed below are added to Article 7 (“Products That May Not Be Imported If Class I Specified Chemical Substances Are Used in Them”) of the Enforcement Order.
| Class I Specified Chemical Substance | Products |
|---|---|
| Long‑chain perfluoroalkanoic acids or their salts | 1.Lubricants 2. Fabrics treated to impart water‑repellency or oil‑repellency 3. Paints 4. Water‑repellent and oil‑repellent agents 5. Adhesives and sealant fillers 6. Fire extinguishers, fire‑extinguishing agents for fire extinguishers, and foam fire‑extinguishing agents 7.Clothing treated to impart water‑repellency or oil‑repellency 8.Floor coverings treated to impart water‑repellency or oil‑repellency 9.Waxes 10.Commercial photographic film |
| Long‑chain PFCA‑related substances | Same as above |
| Chlorpyrifos | Wood preservatives |
| MCCP | 1.Lubricants, cutting oils, and hydraulic oils 2.Additives formulated to impart flame‑retardant properties to fabrics, resins, or rubber 3.Plasticizers for resins 4.Paints 5.Water‑repellent agents and textile protectants 6.Adhesives and sealant fillers |
Designation of Products Required to Comply with Technical Standards
Paragraph 4 of the Supplementary Provisions of the Enforcement Order designates fire extinguishers, fire‑extinguishing agents for fire extinguishers, and foam fire‑extinguishing agents containing “long‑chain perfluoroalkanoic acids or their salts” or “long‑chain PFCA‑related substances” as products specified by Cabinet Order under Article 28(2) of the Act (obligation to comply with standards). Businesses handling these products are required to comply with the technical standards specified by the competent Ministerial Ordinance.
Results of the Public Comment Process and Government Response
Many of the comments submitted on the draft Order expressed concerns about operational burdens and impacts on business activities associated with strengthened regulations. Specific concerns included how to handle trace amounts of long‑chain PFCAs unintentionally generated during manufacturing processes, and requests for grace periods for substances already in use—for example, as refrigerants in semiconductor manufacturing equipment. In response, the government explained the existing operational rule that substances are not treated as Class I Specified Chemical Substances if impurities are reduced to levels that are technically and economically feasible. The government also stated that the use of substances already incorporated into products constitutes “use of products” under the CSCL (and not “use of Class I Specified Chemical Substances”), and therefore did not revise the enforcement date.
Regarding questions about import procedures at customs and disposal rules for products already on the market, the government encouraged stakeholders to consult the relevant customs authorities or the responsible divisions of the MOE. The government also indicated its intention to publish the HS codes for products subject to import prohibition at an early stage. As a result, the government concluded that all comments submitted could be addressed through existing interpretations and operational rules, and no revisions were made to the draft Order based on those comments.
Reference URLs
- Cabinet Order Partially Amending the Enforcement Order of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Cabinet Order No. 171) (Official Gazette, May 22, 2026)
https://www.kanpo.go.jp/20260522/20260522g00113/20260522g001130004f.html - Results of the Public Comment Process on the Draft Cabinet Order
https://public-comment.e-gov.go.jp/pcm/1040?CLASSNAME=PCM1040&id=595126059&Mode=1 - METI News Release on Cabinet Approval of the Cabinet Order (May 19, 2026)
https://www.meti.go.jp/press/2026/05/20260519001/20260519001.html - Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.
https://laws.e-gov.go.jp/law/348AC0000000117/20260701_508AC0000000022?occasion_date=20260701 - Enforcement Order of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.
https://laws.e-gov.go.jp/law/349CO0000000202/20260617_507CO0000000416?occasion_date=20260617
