Japan Extends Technical Standards and Labelling Requirements for Class I Specified Chemical Substances Under the CSCA to LC-PFCAs, Their Salts and Related Substances
On April 17 and May 22, 2026, Japan designated 117 PFHxS-related substances, long-chain perfluoroalkanoic acids (LC-PFCAs) and their salts, medium-chain chlorinated paraffins (MCCPs), and chlorpyrifos as Class I Specified Chemical Substances (Class I SCS)—the most stringent regulatory category under the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., also known as the Chemical Substances Control Act (CSCA).
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.
Extension of Existing PFAS Requirements to LC-PFCAs, Their Salts and Related Substances
On September 1, 2026, Japan proposed amendments to extend existing requirements concerning labelling and technical standards for products containing certain Class I SCS to the newly designated “LC-PFCAs or their salts” and “LC-PFCA-related substances.”
Under the proposed amendment to the Matters to be Labelled on the Containers, Packaging, or Invoices of Products Containing PFOS or its Salts, etc., information currently required to be displayed on the containers, packaging, or accompanying documents/invoices of certain products containing designated Class I SCS would also apply to products containing LC-PFCAs, their salts, and related substances.
The proposal therefore extends the scope of the existing labelling framework rather than introducing a new set of labelling requirements. Businesses handling affected products should review their product portfolios, packaging and supply-chain documentation to determine whether the proposed requirements will apply.
The public consultation is open from September 1 to October 1, 2026.
what are the labelling requirements for designated Class I CSCs?
Additionally, fire extinguishers, fire-extinguishing agents for fire extinguishers, and foam fire-extinguishing agents containing “LC-PFCAs or their salts” or “LC-PFCA-related substances” will be required to comply with the technical standards prescribed under Article 28(2) of the CSCA, as stipulated in Item 1 of the Enforcement Order of the CSCA (Cabinet Order No. 202 of 1974).
The labelling requirements applicable to fire extinguishers, fire-extinguishing agents for fire extinguishers, and foam fire-extinguishing agents containing “LC-PFCAs or their salts” or “LC-PFCA-related substances” are the same as those currently applicable to products containing “PFOS or its salts,” “PFOA or its isomers or their salts,” “PFOA-related substances,” “PFHxS or its isomers or their salts,” or “PFHxS-related substances.” Accordingly, the proposed amendment does not introduce any changes to the content of the information required to be displayed.
Regulatory impact
From 22 November 2026, firefighting products containing “LC-PFCAs or their salts” or “LC-PFCA-related substances” will be subject to the existing technical handling standards applicable to Class I SCS.
Relevant products will also be subject to the existing CSCS labelling requirements. The proposed amendments do not introduce new technical or labelling requirements. Instead, they extend the scope of the existing requirements to the newly designated Class I SCS, “LC-PFCAs or their salts” and “LC-PFCA-related substances.”
Consultation period
The consultation period of both draft amendments runs until 1 October 2026.
Key timelines
Tentative promulgation date: Early November 2026
Tentative enforcement date: 22 November 2026
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.
Related articles:
Other 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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