On May 19, 2026, the Japanese Cabinet approved a revision to the Japanese Chemical Substances Control Law Enforcement Order that will designate chlorpyrifos, medium-chain chlorinated paraffins (MCCP) and long-chain perfluorocarboxylic acids (LC-PFCA), their salts and related compounds, as Class I Specified Chemical Substances, the strictest regulatory tier. Once the order is promulgated and takes effect, manufacture, import and use of these substances will be barred in principle, so makers and importers of pesticides, chlorinated paraffin products and fluorochemicals should prepare to exit them.
Substances Added to the Class I List
The cabinet decision adds four substance groups to the Class I list defined in Article 2, paragraph 2 of the CSCL:
- LC-PFCA and their salts
- LC-PFCA-related substances
- Chlorpyrifos
- MCCP
Class I status applies to chemicals that are persistent, highly bioaccumulative and carry long-term toxicity risks to humans or top predators, the very profile that put these substances on the Stockholm Convention's persistent organic pollutant (POP) agenda.
Key Regulatory Obligations
Class I Specified Chemical Substances carry the heaviest duties under the CSCL.
- Manufacture, import and use are prohibited in principle, with narrow, permit-based exemptions
- Products containing them may not be imported
- Businesses holding existing stock must manage and dispose of it properly
- Annual reporting and record-keeping also attach to any permitted handling
Effective Dates and Transitional Arrangements
The revised order was promulgated on May 22, 2026. The core prohibitions on manufacture, import and use of the four designated substances will take effect on November 22, 2026—six months from the date of promulgation.
Certain transitional measures and other related provisions may enter into force either on the date of promulgation or on the same six-month date, depending on the specific item. Affected businesses should treat November 22, 2026 as the firm deadline for compliance and are strongly advised to complete supply chain screening, substitution planning and compliant inventory disposal well in advance, rather than waiting until the last minute.
Action Items for Affected Companies
Companies in the affected supply chains should now
- Identify whether their products contain chlorpyrifos, MCCP or LC-PFCA compounds
- Plan substitution
- Arrange compliant disposal of inventory ahead of enforcement
