On September 18, 2026, Japan's Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI) and Ministry of the Environment (MOEJ) jointly issued a ministerial ordinance (Ordinance of MHLW, METI and MOEJ No. 6 of 2026), which finalized the "long-chain perfluorocarboxylic acid (LC-PFCA) related substances" under Item 42 of Paragraph (1), Article 1 of the Enforcement Order for the Chemical Substance Control Law (CSCL) as a specific list of substances. The ordinance will take effect on November 22, 2026, when the substances on the list will be designated as Class I Specified Chemical Substances under the CSCL, with their manufacture, import and use prohibited in principle; paint products containing these substances will also be banned from import.
New Listings under the Stockholm Convention; Japan Amends Cabinet Order in Advance
From April to May 2025, the twelfth meeting of the Conference of the Parties to the Stockholm Convention decided to list long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds in Annex A (elimination) of the Convention, covering perfluorocarboxylic acids with carbon chain lengths of C9 to C21. To fulfill its obligations under the Convention, Japan published the Cabinet Order amending the Order for Enforcement of the CSCL on May 22, 2026 (Cabinet Order No. 171 of 2026), adding Item 42 to Article 1, Paragraph (1) of the Order for Enforcement, under which "long-chain perfluorocarboxylic acids (C9 to C21) and their salts" and "LC-PFCA related substances" were designated; chlorpyrifos and medium-chain chlorinated paraffins (MCCPs) were designated as Class I Specified Chemical Substances in the same batch. The specific scope of "LC-PFCA related substances" was authorized to be determined by MHLW, METI and MOEJ in the form of a ministerial ordinance.
Ordinance Clarifies the Scope of Related Substances
The ordinance published this time was formulated under this authorization. It defines "LC-PFCA related substances" as chemical substances whose molecules contain a perfluoroalkyl group (with 8 to 20 carbon atoms) directly bonded to an atom other than fluorine, chlorine, or bromine, and that can generate long-chain perfluorocarboxylic acids through natural chemical changes, excluding PFOA (perfluorooctanoic acid)- related substances. The draft ordinance was open for public comment from June 1 to June 30, 2026, and received three comments; the three ministries published responses to the comments together with the ordinance and made technical amendments to the ordinance text.
Prohibition in Principle with No Concentration Exemption
Class I Specified Chemical Substances are the most strictly controlled category under the CSCL, with manufacture, import and use prohibited in principle. In the responses to the comments, the three ministries clarified that no exemption based on content levels applies to Class I Specified Chemical Substances under the CSCL: even when contained in trace amounts, the corresponding regulation applies once confirmed through analysis. Only where a related substance is present as an impurity and it is confirmed that it will not damage human health through environmental pollution or affect the habitation of animals and plants, and where its content has been reduced to the lowest level technically and economically achievable, will it not be managed as a Class I Specified Chemical Substance.
On the import side, the amending Cabinet Order has listed paints using long-chain perfluorocarboxylic acids and their salts, LC-PFCA related substances or medium-chain chlorinated paraffins, among other products, as products banned from import, taking effect on November 22, 2026 together with the ordinance. The HS codes corresponding to the banned products will be published separately by METI on its dedicated webpage for import customs clearance procedures under the CSCL.
ChemRadar Insights
The Japan Paint Manufacturers Association has called on its member companies to urgently screen their own raw materials. Companies exporting paints, paint raw materials and related fluorinated products to Japan are advised to carry out the following work as soon as possible:
- Screen raw materials and formulations: Against the scope of related substances defined by the ordinance, check whether fluorinated substances capable of generating LC-PFCAs (C9 to C21) exist in products and the raw material chain; where necessary, ask suppliers for ingredient lists or safety data sheets (SDSs) for confirmation.
- Note the absence of concentration exemptions: Even if a product contains trace amounts of a listed substance, confirmation may trigger requirements such as the import ban; although impurities are subject to separate treatment rules, item-by-item evaluation based on supplier information is also recommended.
- Track the HS code list: Follow up on the HS codes of the banned products to be published later on METI's dedicated webpage for import customs clearance procedures, and check whether the codes of products exported to Japan are restricted.
- Use the window before the ordinance takes effect: About two months remain before the ordinance takes effect on November 22. For formulations involving fluorine-based raw materials used in water and oil repellency, surface coating treatment and similar applications, complete substitution assessment and adjustment as soon as possible, so that products containing the related substances will not be unable to enter Japan after the ordinance takes effect.
