Japan Expands PFAS and POPs Controls Under CSCA: PFHxS-Related Substances, LC-PFCAs, MCCPs and Chlorpyrifos Designated as Class I Specified Chemical Substances
- May 31
- 5 min read
Japan continues to strengthen its chemical management framework under the Chemical Substances Control Act (CSCA), introducing significant new restrictions on per- and polyfluoroalkyl substances (PFAS) and Persistent Organic Pollutants (POPs) in 2026.
The latest amendments expand the scope of substances designated as Class I Specified Chemical Substances (Class I SCS)—the most stringent regulatory category under the CSCA—resulting in broad prohibitions on the manufacture, import, use, and importation of certain products containing these substances.
What are Class I SCS?
Class I SCS are substances that are persistent, highly bioaccumulative, and have a risk of long-term toxicity to humans or predator animals at higher trophic level, and are specified by the Cabinet Order (Order for enforcement of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.)
Restrictions
The manufacture and import of such substances are generally prohibited, in principle, unless specifically authorized by the relevant authorities. Their use is strictly limited to the essential uses explicitly permitted under the law, and any other use is prohibited.
In addition, the import of products or articles containing these substances, as specified by Cabinet Order, is prohibited. Where a substance or product is designated under the regulation, or where a violation of the law is identified, the competent authority may order corrective actions, including the recall of affected products and other necessary measures to prevent risks to human health and the environment.
117 PFHxS-Related Substances Designated as Class I SCS
On 17 April 2026, Japan promulgated a ministerial ordinance designating 117 PFHxS-related substances as Class I Specified Chemical Substances. The ordinance entered into force on 17 June 2026.
The designation follows the inclusion of perfluorohexane sulfonic acid (PFHxS), its salts, and related compounds under the Stockholm Convention on Persistent Organic Pollutants and represents Japan's implementation of its international obligations.
The newly regulated substances include various salts, derivatives, polymers, reaction products, and precursor substances capable of degrading into PFHxS through environmental transformation processes.
Applicable Scope
PFHxS-related substances are defined as compounds that:
Contain either a (tridecafluoroalkyl) sulfonyl group with six carbon atoms, or a [(tridecafluoroalkyl) sulfinyl] oxy group with six carbon atoms; and
May generate perfluoro(hexane-1-sulfonic acid) or certain perfluoroalkane sulfonic acids through chemical transformation by natural processes.
Regulatory Impact
The designation introduces significant compliance obligations for industry:
Manufacture, import, and use of the 117 substances are prohibited in principle.
Products containing these substances may be subject to import restrictions.
Companies must assess not only intentionally added substances but also impurities, intermediates, polymers, and degradation products that may fall within scope.
Industries that previously transitioned away from PFOS may be particularly affected, as some replacement fluorinated chemistries could now fall within the PFHxS-related substance definition.
LC-PFCAs, MCCPs, and Chlorpyrifos Added to the Class I SCS List
Japan further expanded the Class I SCS list on 22 May 2026 through amendments to the CSCA Enforcement Order. These amendments will enter into force on 22 November 2026.
The following substances have been designated as Class I SCS:
Long-chain perfluoroalkane carboxylic acids (LC-PFCAs; C9–C21) and their salts
LC-PFCA-related substances capable of degrading into LC-PFCAs
Medium-chain chlorinated paraffins (MCCPs)
Chlorpyrifos
LC-PFCAs become the fourth major PFAS group regulated under Japan's CSCA, following PFOS, PFOA, and PFHxS.
The amendment reflects decisions adopted at the Twelfth Conference of the Parties (COP12) to the Stockholm Convention, which identified these substances for global elimination due to their persistence, bioaccumulative properties, long-range environmental transport potential, and toxicity.
Expanded Product Controls
The amendments extend beyond substance restrictions and directly affect finished products entering the Japanese market.
Products that may not be imported if they contain regulated substances include:
Lubricants and related products containing LC-PFCAs, LC-PFCA-related substances, or MCCPs
Wood insecticides containing Chlorpyrifos
In addition, Japan has introduced technical standards applicable to certain firefighting equipment, fire-extinguishing agents, and firefighting foams containing LC-PFCAs and related substances during the transition period.
Increasing Regulatory Focus on PFAS Precursors
A notable trend across these amendments is Japan's shift from regulating individual PFAS substances toward broader regulation of PFAS precursors and degradation products.
Consistent with the regulatory approaches previously adopted for PFOA-related compounds and PFHxS-related substances, the LC-PFCA framework captures substances capable of degrading into regulated PFAS through environmental processes.
This approach significantly broadens the scope of compliance obligations and requires companies to evaluate raw materials, formulations, manufacturing processes, and supply chains beyond explicitly listed substances.
Key Business Implications
These amendments represent one of Japan's most significant expansions of PFAS regulation in recent years and further align the country's regulatory framework with international POPs elimination initiatives under the Stockholm Convention.
Companies manufacturing, importing, or supplying products into Japan should:
Review product formulations for regulated PFAS and POPs.
Assess PFAS precursor substances and transformation products.
Engage suppliers to obtain updated substance declarations and compliance information.
Evaluate imported articles and finished products for potential compliance risks.
Monitor future ministerial ordinances that may further define the scope of LC-PFCA-related substances and associated product restrictions.
Penalties for Non-Compliance
Violations involving Class I Specified Chemical Substances are subject to significant penalties under the CSCA.
Individuals
Imprisonment for up to three years;
A fine of up to JPY 1 million (approximately USD 6,300); or
Both imprisonment and a fine.
Corporations
A fine of up to JPY 100 million (approximately USD 627,000) under the corporate liability provisions.
These penalties may apply to violations involving the manufacture, import, use, or importation of prohibited products containing Class I Specified Chemical Substances.
Looking Ahead
With key enforcement dates occurring throughout 2026, organizations should begin supply chain assessments, substance inventories, and reformulation activities as early as possible to minimize disruption and ensure continued access to the Japanese market.
Taken together, these measures further establish Japan as one of the leading jurisdictions in the Asia-Pacific region implementing comprehensive PFAS and POPs controls, with an increasing emphasis on precursor substances, imported articles, and supply chain transparency.
Related articles:
Cabinet Order to Partially Amend the Enforcement Order of the Act on the Examination and Regulation of Manufacture, etc., of Chemical Substances.", Designating LC-PFCA and its salts, LC-PFCA-related substances, Chlorpyrifos, and Medium-chain Chlorinated Paraffin (MCCP) as Class I Specified Chemical Substances (Official Gazette of Japan, May 22, 2026 (Cabinet Order No. 171)
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