Participation Report: Taiwan’s Ministry of Environment Holds Seminar on Proposed Adjustments to the Draft “Regulated PFAS and Their Handling Management Matters” 
On June 24, 2026, the Chemical Substance Management Administration of Taiwan’s Ministry of Environment held a seminar regarding the proposed adjustments to the draft Regulated PFAS and Their Handling Management Matters, which was originally announced in August 2025. Our staff participated in this seminar online. According to the authorities, more than 40 comments were received during the public comment period for the draft, including submissions from Japanese companies. Our company, EnviX, was also invited to this seminar as we had previously submitted an inquiry regarding whether articles would be subject to the regulations.
The seminar featured an introduction to the contents of the proposed adjustments, as well as responses to the collected comments and questions. The proposed adjustments mainly consist of six key points: (1) reduction of regulated substances, (2) raising of the regulatory concentration limit, (3) standardization of labeling text on containers and packaging materials, (4) addition of exempted items, (5) revision of the enforcement date, and (6) extension of the deadlines for compliance obligations. Among these, the most notable change is the plan to reduce the number of regulated substances from the original 269 types to 182 types.
Background of the Draft Adjustments
Taiwan’s Ministry of Environment announced the draft Regulated PFAS and Their Handling Management Matters on August 5, 2025, and also issued a WTO/TBT notification on September 15, 2025. More than 40 comments were received in response to this draft. Based on these opinions, the Ministry of Environment held an expert seminar on May 8, 2026, to deliberate on the proposed adjustments to the draft. As the most significant adjustment, a policy was adopted to “temporarily put on hold” the substances currently under debate.
Main Adjustment Contents
The following six adjustment contents were primarily introduced during this seminar:
1. Reduction of Regulated Substances
With reference to the list of substances covered by the POPs Convention, the OECD’s definition of PFAS, and international management scopes, the following adjustments were made:
- 14 POPRC21 substances slated to be added to toxic substances:
14 substances subject to POPRC21, such as perfluorododecanoic acid (CAS No.: 307-55-1) and perfluoro-C8-14-alkyl alcohols (CAS No.: 68391-08-2), are scheduled to be separately added as “toxic substances.” Therefore, they have been removed from the current list. - 14 substances not meeting the OECD definition put on hold:
With reference to the OECD definition and international management statuses, substances that do not fit the OECD definition have been put on hold and removed from the current list in order to further evaluate whether they should remain subject to regulation in the future. - 34 PFAS polymer substances put on hold:
With reference to the polymer list in the Annex of the OECD’s 2025 report, these substances have been removed from the current list to further evaluate whether they should remain subject to regulation in the future. - 32 PFAS gas substances put on hold:
Due to an overlap issue where the PFAS gas substances in Attached Table 3 duplicate regulated substances under the “Climate Change Response Act,” they have been removed from the current list of regulated substances to continuously evaluate whether they should be targeted.
Note: The 32 types mentioned above include 7 POPRC21 substances and substances that do not meet the OECD definition. - Reclassification of hexafluoropropene trimer to “PFAS polymer substance”:
Based on industry feedback and relevant international definitions, the classification of hexafluoropropene trimer (CAS No.: 6792-31-0) was changed from “PFAS gas” to “PFAS polymer substance.”
2. Raising of the Regulatory Concentration Limit
In the original draft, the regulatory concentration limit for targeted substances was set at 0.1 w/w%. However, because discussions regarding the carcinogenicity, germ cell mutagenicity, and reproductive toxicity (CMR) of these substances are still ongoing, the regulatory concentration limit has been raised to 1 w/w%. In other words, substances with a concentration exceeding 1 w/w% will be subject to regulation.
3. Standardization of Labeling Text on Containers and Packaging Materials
In the original draft, different labeling texts were prescribed for containers and packaging materials depending on whether the substances belonged to Attached Table 1 (“Perfluoroalkyl acids, their precursors, and other perfluoroalkyl compounds and polyfluoroalkyl compounds”), Attached Table 2 (“Polymers”), or Attached Table 3 (“Gases”). However, under the current proposed adjustments, the labeling text for Attached Table 1 and Attached Table 2 has been standardized to “Perfluoroalkyl and Polyfluoroalkyl Substances” (Chinese: 全氟及多氟烷基物質), while the entirety of Attached Table 3 has been deleted.
4. Addition of Exempted Items
Article 5 of the draft explicitly stated that substances or articles regulated by 20 specific laws, such as the “Commodity Inspection Act” and the “Medical Devices Act,” are outside the scope of this public notice. In the current proposed adjustments, the “Fire Services Act” has been added to this article, clarifying that substances or articles regulated by the “Fire Services Act” are also excluded from this public notice.
5. Postponement of the Enforcement Date by One Year
Although the original draft stated that the regulation would enter into force on January 1, 2026, its official promulgation had been delayed due to the emergence of the various discussion points mentioned above. According to the contents of the proposed adjustments distributed this time, the enforcement date has been revised to January 1, 2027.
6. Extension of Deadlines for Compliance Obligations
Annexed Document 4 of the draft stipulates matters that must be completed within designated timeframes. Accompanying the postponement of the promulgation date, the deadlines for each compliance matter have also been extended. The new deadlines set forth in the proposed adjustments are as follows:
| Regulated Matter | Completion Deadline |
|---|---|
| Labeling on containers, packaging, handling areas/facilities, and preparation of SDS | January 1, 2029 |
| Acquisition of authorization documents for designated activities such as manufacturing, import, sale, use, and storage | January 1, 2029 |
| Keeping records of handling | January 1, 2027 |
| Other matters | Required to be addressed from the date of enforcement |
Will Molded Articles Be Subject to Regulation?
Many companies had submitted inquiries regarding whether articles would fall within the scope of this regulation. During the Q&A session of the seminar, the official in charge from the authority provided a clear response as follows: “The scope of regulation under the Toxic and Concerned Chemical Substances Control Act (TCCSCA) is chemical substances (chemical raw materials). Furthermore, substances or articles regulated by the 20 laws stipulated in Article 5 of this public notice, such as the Commodity Inspection Act and the Medical Devices Act, are also exempt from this regulation.”
EnviX Comment
Approximately 360 people participated in this seminar, and the high turnout reflects the immense interest in this matter. Whether articles would be covered had been a point of high concern for a long time. Through this seminar, it was clearly communicated that articles are outside the scope of both the “TCCSCA” and this public notice, which successfully cleared up the doubts held by many companies.
The original documents of the draft adjustments released at this seminar, the seminar slides (including the Q&A contents), and the comparison table for the adjustments to the regulated substance list can be downloaded from the following URL (Traditional Chinese):
https://www.cha.gov.tw/sp-event-form-412-1e23a-1.html
