On June 24, 2026, the Chemical Substance Management Agency (CSMA) of Taiwan's Ministry of Environment convened a consultation meeting on the draft 'Control of Listed Per- and Polyfluoroalkyl Substances and Their Operation Management,' announcing adjustments to the draft PFAS (per- and polyfluoroalkyl substances) controls. The revised plan proposes newly listing 14 substances as toxic chemical substances with reference to the Stockholm Convention, 182 as concerned chemical substances, and placing 73 under continued assessment, while postponing the effective date from the originally planned early 2026 to January 1, 2027, with an additional two-year grace period.
Background of the Draft
The draft was pre-announced on August 5, 2025 (Environmental and Chemical Department No. 1148109932). Pursuant to Article 24, Article 26 Paragraph 2, Article 27 Paragraph 2, and Article 44 Paragraph 4 of the Toxic and Concerned Chemical Substances Control Act of Taiwan, the draft proposed to list 269 PFAS as concerned chemical substances and to set control concentrations and operation requirements, with an original effective date of January 2026.
Adjustments to the Scope of Listed Substances
The adjustments announced at the consultation meeting involve the following three measures:
- 14 newly added toxic chemical substances: To be listed as toxic chemical substances with reference to the Stockholm Convention, subject to stricter controls than concerned chemical substances; the specific substances shall be subject to the annexes officially announced by the Chemical Substance Management Agency.
- 182 concerned chemical substances: Subject to controls slightly less stringent than those for toxic chemical substances, with the focus on grasping their specific uses and operator information.
- 73 substances under continued assessment: Fluoropolymers, PFAS gases, and substances not meeting the definition of the Organisation for Economic Co-operation and Development (OECD) will continue to be assessed, in light of refrigerant substitution, industry impact, and other factors.
Scope of Application and Exemptions
The draft clarifies that the TCCSCA core regulates only chemical raw materials, while finished products, commodities, and articles governed by 21 existing laws, including the Pesticide Control Act, are comprehensively excluded and require no declaration or labeling. At the consultation meeting, in response to questions on whether finished products such as pen refills, semiconductor wafers, and home appliance components fall within the scope of control, the Chemical Substance Management Agency confirmed that the above finished products are not within the scope of control.
Effective Date and Grace Period
The draft was originally scheduled to take effect in early 2026; the consultation meeting confirmed a postponement to January 1, 2027, and set a two-year grace period, giving relevant enterprises time to obtain approval permits, complete labeling, and fulfill declaration and other supporting obligations.
ChemRadar Insights
In light of the adjustments above, enterprises handling PFAS in Taiwan are advised to focus on the following compliance matters:
- Verify the scope of control: Enterprises that manufacture, import, or use PFAS-containing chemical substances (particularly raw materials) in Taiwan should verify whether the substances concerned fall within the proposed list of 14 toxic chemical substances or 182 concerned chemical substances. The specific names and CAS numbers of the 14 toxic substances and 182 concerned chemical substances were not identified in the report, and shall be subject to the annexes to be officially announced by the Chemical Substance Management Agency (the June 24 consultation meeting only reflected the adjustment intention; the formally revised annexes have not yet been released).
- Determine product form: Finished products, commodities, and articles governed by the existing 21 laws are not within the scope of this draft and require no declaration or labeling; enterprises should first determine whether their own products are raw materials or finished products.
- Make use of the grace period: With the draft postponed to take effect on January 1, 2027 and a two-year grace period set, relevant enterprises should complete the relevant compliance preparations within this window.
- Track subsequent classification: Industries related to fluoropolymers, PFAS gases, and refrigerant substitutes should monitor the subsequent classification developments of the 73 substances under continued assessment, so as to guard against being additionally listed later.
