On April 17, 2026, Japan's Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment (MOE) jointly promulgated a ministerial ordinance officially designating 117 perfluorohexanesulfonic acid (PFHxS)-related substances as Class I Specified Chemical Substances under Chemical Substance Control Law (CSCL), effective June 17, 2026. From that date, the manufacture, import, and use of these substances will be prohibited in principle, and Cabinet-Order-designated products containing such substances will also be banned from import into Japan. Enterprises in sectors such as fluorochemicals, surface treatment, water- and oil-repellent textile finishing, fire-extinguishing agents, and semiconductors should conduct compliance assessments and adjust their supply chains in advance.
Background
PFHxS is a per- and polyfluoroalkyl substance (PFAS) that is persistent, highly bioaccumulative, and chronically toxic. In June 2022, the tenth meeting of the Conference of the Parties (COP10) to the United Nations Stockholm Convention on Persistent Organic Pollutants added PFHxS and its related substances to the list of persistent organic pollutants scheduled for elimination. Japan's designation of these substances as CSCL Class I Specified Chemical Substances is a domestic implementing measure to fulfill its obligations under the Convention, and represents another stringent control on PFAS substances, following PFOS and PFOA.
Key Regulatory Points
The designation was finalized through a two-step process: a Cabinet Order and a ministerial ordinance.
- Cabinet Order: On December 17, 2025, Japan promulgated the Cabinet Decision on a Cabinet Order Amending Certain Provisions of the Enforcement Order of the Act on the Review and Control of the Manufacture of Chemical Substances, which added Item 37 to Article 1, Paragraph 1 of the Enforcement Order, incorporating “PFHxS-related substances” as a substance group into Class I Specified Chemical Substances; the substantive provisions take effect on June 17, 2026.
- Ministerial Ordinance: On April 17, 2026, the three ministries jointly promulgated the Ministerial Ordinance Designating Chemical Substances Pursuant to Article 1, Item 1, No. 37 of the Enforcement Order of the Act on the Review and Control of Chemical Substances, which enumerates the 117 specific PFHxS-related substances and takes effect on June 17, 2026.
PFHxS-related substances are substances that can generate perfluorohexanesulfonic acid (PFHxS), etc., through chemical change under natural conditions; the ministerial ordinance lists all 117 substances individually by name in the Official Gazette (no CAS numbers are recorded there).
Regulatory Consequences
As CSCL Class I Specified Chemical Substances, the 117 PFHxS-related substances will be subject to the following controls from June 17, 2026:
- Manufacture, import, and use are prohibited in principle; where manufacture or import is genuinely necessary, permission must be applied for in accordance with the law (in practice, limited to approved cases);
- Cabinet-Order-designated products containing the above substances are banned from import into Japan;
- For fire extinguishers and fire-extinguishing agents, compliance with the relevant technical standards is required (not a blanket ban).
ChemRadar Insights
As the list of 117 substances published in the ministerial ordinance is given by substance name and the Official Gazette does not include CAS numbers, enterprises are advised to compare their products and raw materials item by item to determine whether any PFHxS-related substances are involved. If so, they should evaluate alternatives and adjust their export to Japan and supply chain arrangements as early as possible, and complete any necessary permission applications or use verifications before the June 17 effective date.
