On February 2, 2026, Japan's Ministry of Economy, Trade and Industry (METI) issued a notification, deciding to designate three substances as Class I Specified Chemical Substances under the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (Chemical Substances Control Law, CSCL). These substances include chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), long-chain perfluorocarboxylic acids (long-chain PFCAs) and their salts and related substances. The associated implementation schedule was also announced.
At the 12th Conference of the Parties (COP12) to the Stockholm Convention held between April and May 2025, chlorpyrifos, MCCPs, long-chain PFCAs and their salts and related substances were listed in Annex A (Elimination) of the Convention. Based on this decision, Japan's Council on Chemical Substances decided in June 2025 to designate the aforementioned substances as Class I Specified Chemical Substances under the CSCL.
Subsequently, at a Council on Chemical Substances meeting held in September 2025, it was further clarified that the manufacture, import, and use of these substances should be prohibited, except for testing and research purposes, and no applicable exemptions would be established. The meeting also identified the relevant product categories subject to the import ban and the scope of products required to meet technical standards.
Furthermore, based on the above conclusions, the process for official promulgation and enforcement will proceed after completing procedures such as public consultation on the draft amendment to the relevant Cabinet Order.
Future Schedule
The amendment to the Cabinet Order concerning the designation of the above substances as Class I Specified Chemical Substances and the related import ban is expected to take effect around autumn 2026. Companies using these substances are advised to promptly begin evaluating and preparing alternative solutions. The tentative schedule is as follows:
- After January 2026: Public consultation on the Draft Cabinet Order for Partial Revision of the CSCL Enforcement Order.
- Around Spring 2026: Promulgation of the amended Cabinet Order. Joint meeting of three ministries (MHLW, METI, MOE) to deliberate on the designation matters concerning long-chain PFCA-related substances.
- After Summer 2026: Promulgation of the Ministerial Ordinance concerning the designation of long-chain PFCA-related substances.
- Around Autumn 2026: Enforcement of the amended Cabinet Order and the Ministerial Ordinance concerning the designation of long-chain PFCA-related substances.
Once chlorpyrifos, MCCPs, long-chain PFCAs, etc., are designated as Class I Specified Chemical Substances, their use will be comprehensively prohibited, except for specific exceptional purposes. This prohibition includes companies using them as raw materials to produce other chemicals or products.
Substances Proposed for Designation as Specified Chemical Substances and Products Subject to Import Ban:
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Substances Proposed as Class I Specified Chemical Substances |
Products Subject to Import Ban |
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Chlorpyrifos (O,O-diethyl O-(3,5,6-trichloro-2-pyridyl) phosphorothioate) |
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Medium-Chain Chlorinated Paraffins (including substances or mixtures meeting condition (1) and/or (2) below): (1) Substances or mixtures containing linear chlorinated alkanes with a carbon chain length of 14-17 and a chlorine content ≥ 45% by weight. (2) Substances or mixtures containing linear chlorinated alkanes with a carbon chain length of 14-17 conforming to the following molecular formulas: C₁₄H₍₃₀₋ᵧ₎Clᵧ （y ≥ 5） C₁₅H₍₃₂₋ᵧ₎Clᵧ （y ≥ 5） C₁₆H₍₃₄₋ᵧ₎Clᵧ （y ≥ 6） C₁₇H₍₃₆₋ᵧ₎Clᵧ （y ≥ 6） |
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Perfluoroalkyl carboxylic acids (limited to compounds with 9-21 carbon atoms) (alias: long-chain PFCAs) and their salts, as well as long-chain PFCA-related substances (referring to compounds possessing a perfluoroalkyl group (limited to groups with 8-20 carbon atoms) directly attached to an atom other than fluorine, chlorine, or bromine, and which are chemical substances capable of transforming via natural processes to generate perfluoroalkyl carboxylic acids (limited to compounds with 9-21 carbon atoms), as specified by ordinances of the Ministry of Health, Labour and Welfare, the Ministry of Economy, Trade and Industry, and the Ministry of the Environment). |
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