On March 20, 2026, pursuant to the Chemical Substances Control Law (CSCL), Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment (MOE) jointly issued a Cabinet Order (draft) to partially amend the Enforcement Order of the CSCL, designating multiple chemical substances as Class I Specified Chemical Substances and clearly specifying products subject to import prohibition.
Partial Amendment to the Enforcement Order of the CSCL (Cabinet Order Draft)
Background
At the 12th meeting of the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants, held from April to May 2025, it was decided to list long-chain perfluoroalkyl carboxylic acids and their salts, long-chain perfluoroalkyl carboxylic acid-related substances, chlorpyrifos, and medium-chain chlorinated paraffins (MCCPs) as substances to be eliminated.
Accordingly, the Pharmaceutical Affairs Council of the Ministry of Health, Labour and Welfare, the Chemical Substances Council of the Ministry of Economy, Trade and Industry, and the Central Environment Council of the Ministry of the Environment have determined that these substances should be newly designated as Class I Specified Chemical Substances under the CSCL. Consequently, the Enforcement Order of the said law will be amended.
Class I Specified Chemical Substances are those that are persistent, highly bioaccumulative, and pose a risk of long-term toxicity to humans or higher predators, and are designated by Cabinet Order. Once designated as Class I Specified Chemical Substances, their manufacture, import, and use are generally prohibited, as is the import of products containing such substances.
Key Provisions
- Designation of the following chemical substances as Class I Specified Chemical Substances (Article 1, Paragraph 1 of the Cabinet Order)
- Perfluoroalkyl carboxylic acids (limited to compounds with 9 to 21 carbon atoms) (also known as LC-PFCA; hereinafter referred to as long-chain perfluoroalkyl carboxylic acids or their salts)
- Long-chain perfluoroalkyl carboxylic acid-related substances (chemical substances that contain a perfluoroalkyl group with 8 to 20 carbon atoms directly bonded to an atom other than fluorine, chlorine, or bromine, and that undergo chemical changes through natural processes to generate long-chain perfluoroalkyl carboxylic acids, as specified by Ordinances of the MHLW, METI, and MOE; excluding perfluorooctanoic acid-related substances)
- O,O-diethyl O-(3,5,6-trichloro-2-pyridyl) phosphorothioate (also known as chlorpyrifos)
- Polychlorinated straight-chain paraffins (limited to substances with 14 to 17 carbon atoms and a chlorine content of 45% or more by molecular weight) (also known as MCCP)
- Designation of products subject to import prohibition among products containing the newly designated substances (Article 7 of the Cabinet Order)
|
Substance |
Products Subject to Import Prohibition |
|
Long-chain perfluoroalkyl carboxylic acids or their salts |
|
|
Chlorpyrifos |
|
|
MCCP |
|
- Designation of products subject to compliance with technical standards and labeling obligations for products containing the following substances (Item 4 of the Supplementary Provisions of the Cabinet Order)
|
Substance |
Products |
|
Long-chain perfluoroalkyl carboxylic acids or their salts |
Fire extinguishers, fire extinguishing agents, and foam extinguishing agents |
|
Long-chain perfluoroalkyl carboxylic acid-related substances |
Fire extinguishers, fire extinguishing agents, and foam extinguishing agents |
- Establishment of necessary transitional measures in the Supplementary Provisions of the amending Cabinet Order (Items 2 and 3 of the Supplementary Provisions)
Article 2: The Minister of Health, Labour and Welfare, the Minister of Economy, Trade and Industry, and the Minister of the Environment may, prior to the enforcement of this Cabinet Order, consult councils, etc. on drafts of the Ordinances of the Ministry of Health, Labour and Welfare, Ministry of Economy, Trade and Industry, and Ministry of the Environment pertaining to long-chain perfluoroalkyl carboxylic acid-related substances as amended by this Cabinet Order.
Article 3: For acts performed prior to the enforcement of this Cabinet Order, penalties shall continue to be applied according to the prior provisions.
Schedule (Planned)
Date of promulgation: Around May 2026
Date of enforcement: Around May 2026 (for transitional measures); Around November 2026 (full enforcement)
Public Comment
Comments will be accepted from March 20, 2026, to April 18, 2026, via the contact information provided on the official websites.
Further Information
