On 2 October 2026, Japan’s Ministry of Economy, Trade and Industry (METI) issued a notice announcing that, as the Cabinet Order amending the Enforcement Order of the Chemical Substances Control Law (CSCL) (Cabinet Order No. 171 of 2026, promulgated on 22 May 2026) comes into full effect on 22 November 2026, import customs clearance procedures for chemical substances under the CSCL will be conducted in accordance with the new rules, and the previous notice (issued on 2 June 2026) will apply only until 21 November 2026. After the update, four newly designated Class I Specified Chemical Substances—long-chain perfluorocarboxylic acids (LC-PFCAs) and their salts, LC-PFCA-related substances, chlorpyrifos, and medium-chain chlorinated paraffins (MCCPs)—will be included in the import clearance screening list; products using LC-PFCAs and other listed substances, such as lubricants, coatings, water- and oil-repellent treated textiles, and fire extinguishers, will also be included in the cross-reference table of products prohibited from import and may no longer be imported from the same date.
Background: Four Substances Designated as Class I Specified Chemical Substances
Cabinet Order No. 171 was decided at a Cabinet meeting on 19 May 2026 and promulgated on 22 May 2026. It designates LC-PFCAs and their salts, LC-PFCA-related substances, chlorpyrifos, and MCCPs as Class I Specified Chemical Substances under the CSCL, simultaneously designates the products using these substances as prohibited from import, and provides that, at the current stage, fire extinguishers, fire extinguishing agents for fire extinguishers, and foam fire extinguishing agents using LC-PFCAs or LC-PFCA-related substances must, when used and handled, comply with the technical standards established by the national government (Article 4 of the Supplementary Provisions of the CSCL Enforcement Order). Under the CSCL, Class I Specified Chemical Substances refer to chemical substances that are persistent, highly bioaccumulative, and have long-term toxicity to humans or higher predatory animals; in principle their manufacture and import are prohibited, and permission is granted only for uses falling under statutory circumstances such as experimental research.
Four Substances Added to the Import Clearance Screening List
The notice expands the import clearance screening list of Class I Specified Chemical Substances under the CSCL (Attachment 1) from 40 to 44 entries. The four newly added substances, together with their official gazette integrated numbers and their classifications under the Schedule to the Customs Tariff Law, are as follows:
|
No. |
Class I Specified Chemical Substance |
Official Gazette Integrated Number |
Classification under the Schedule to the Customs Tariff Law |
|
41 |
Perfluoroalkanoic acids (only those with 9 to 21 carbon atoms; also known as LC-PFCAs, i.e., long-chain perfluorocarboxylic acids) or their salts |
2-2659 |
2915.90 |
|
42 |
LC-PFCA-related substances: compounds having a perfluoroalkyl group (only those with 8 to 20 carbon atoms) directly bonded to an atom other than fluorine, chlorine or bromine, which are designated by Orders of the Ministry of Health, Labour and Welfare, the Ministry of Economy, Trade and Industry and the Ministry of the Environment as substances that generate LC-PFCAs through chemical changes caused by natural actions (excluding PFOA-related substances) |
2-3502, etc. |
2903.78, 2903.79, 2905.59, 2909.49, 2915.90, 2916.14, 2916.12, etc. |
|
43 |
O,O-Diethyl O-(3,5,6-trichloro-2-pyridyl) phosphorothioate (also known as chlorpyrifos) |
5-3724 |
2933.39 |
|
44 |
Polychlorinated straight-chain alkanes (only those with 14 to 17 carbon atoms and a chlorine content of 45% or more by molecular weight) (also known as medium-chain chlorinated paraffins, MCCPs) |
2-68 |
2903.19 |
Cross-Reference Table of Products Prohibited from Import Expanded in Parallel
Under Article 24 of the CSCL, products designated by Cabinet Order as using Class I Specified Chemical Substances may not be imported. The notice expands in parallel the cross-reference table between the products prohibited from import and the Schedule to the Customs Tariff Law (Attachment 2). The additions involve:
- LC-PFCAs or their salts and LC-PFCA-related substances: ten categories of products in total, namely lubricants; water- and oil-repellent treated fabrics; coatings; waterproofing agents and oilproofing agents; adhesives and sealing fillers; fire extinguishers, fire extinguishing agents for fire extinguishers, and foam fire extinguishing agents; water- and oil-repellent treated clothing; water- and oil-repellent treated floor coverings; polishing waxes; and photographic film for business use;
- Chlorpyrifos: insecticides for wood;
- MCCPs: six categories of products in total, namely lubricants, cutting oils and hydraulic oils; formulated additives for imparting flame retardancy to fabrics, resins or rubber; plasticizers for resins; coatings; waterproofing agents and fiber protectants; and adhesives and sealing fillers.
The specific tariff codes corresponding to each category of product are subject to those listed in Attachment 2 of the notice.
Key Points of the Customs Clearance Procedures
The notice also sets out the import customs clearance procedures for each category of chemical substance from 22 November 2026:
- Class I Specified Chemical Substances (including the four newly added substances): the permission of the Minister of Economy, Trade and Industry under Article 22 of the CSCL must be obtained before import, and the permit certificate (a copy is acceptable) must be submitted at the time of import declaration;
- Chemical substances for experimental research and new chemical substances used as reagents: a use confirmation in Form 1 must be submitted at the time of import declaration;
- General chemical substances: the official gazette integrated number must be entered on the import declaration form or the invoice; for monitoring chemical substances and priority assessment chemical substances, the official gazette serial number must be entered;
- Class II Specified Chemical Substances: the item number of each substance prescribed in Article 2 of the Enforcement Order must be entered; in addition, the planned import quantity must be reported to the Minister of Economy, Trade and Industry every year, and where the import exceeds the reported quantity, change procedures must be completed;
- New chemical substances: notification must be completed in advance with the Minister of Health, Labour and Welfare, the Minister of Economy, Trade and Industry, and the Minister of the Environment, and the review or confirmation must be received; copies of the corresponding supporting documents must be submitted at customs clearance. For small-amount new chemical substances and low production volume new chemical substances, a cumulative quantity confirmation in Form 2 must also be submitted.
The notice emphasizes that where the above documents are not submitted, or where the correspondence between the chemical substances described in the documents and those described in the invoice or other documents is unclear, the import may not be permitted.
ChemRadar Insights
For enterprises exporting chemicals and related products to Japan, ChemRadar advises:
- Check whether the exported substances fall within the four newly added substances. From 22 November 2026, the export of LC-PFCAs and their salts, LC-PFCA-related substances, chlorpyrifos, or MCCPs to Japan requires prior import permission; since import permission for Class I Specified Chemical Substances is limited to uses falling under statutory circumstances such as experimental research, conventional commercial imports can in principle not be granted;
- Check product formulations. The ten categories of products containing LC-PFCAs or LC-PFCA-related substances, such as lubricants, coatings, water- and oil-repellent treated fabrics and clothing, and fire extinguishers; the six categories of products containing MCCPs, such as lubricants, cutting oils and hydraulic oils, plasticizers, and coatings; and wood insecticides containing chlorpyrifos may no longer be exported to Japan from the effective date, and related orders should be adjusted before that date;
- Prepare customs clearance documents in full. After the new rules take effect, customs will carry out verification against the new lists; the correspondence between the declaration documents and the cargo information needs to be clear and complete, so as to avoid clearance obstruction.
