Japan consults to designate PFHxS-related substances as Class I Specified Chemicals

On 16 September 2025, Japan released draft Cabinet Order which amends parts of the Enforcement Order of the Chemical Substances Control Law (CSCL). This aligns the decision at the 10th Conference of the Parties (COP10) to the Stockholm Convention on Persistent Organic Pollutants (June 2022) to eliminate Perfluorohexane sulfonic acid (PFHxS)-related substances. Following review by Japan’s three relevant ministries—the Ministry of Health, Labour and Welfare (MHLW), the Ministry of Economy, Trade and Industry (METI), and the Ministry of the Environment (MoE)-these substances will be designated as Class I Specified Chemical Substances under CSCL. This designation prohibits their manufacture, import, and use, as well as the import of products containing them.

Previous update in August 2024

Earlier on 1 August 2024, Japan’s MHLW, METI and MoE jointly released the draft for designating PFHxS-related substances as Class I Specified Chemicals under CSCL. Also importing the products containing PFHxS-related chemicals will be banned. More information can be found here.

Key Changes from the draft

The provisions which are proposed in the draft are:

• PFHxS-related substances designated as Class I Specified Chemicals → Manufacture, import, and use banned.
• Import bans on products containing these substances.
• Exemption removed for 8:2 Fluorotelomer Alcohol (no longer considered “difficult to substitute”).
• Technical standards & labelling rules updated accordingly.
• Transitional provisions included.

Obligations for Stakeholders

Once designated as a Class I Specified chemical, PFHxS or related chemicals will be prohibited to manufacture, import, and use, as well as the import of products containing them. Stakeholders need to search for alternatives to PFHxS or apply for specific permit to continue the activities.

Comment Period and Enforcement Dates

Stakeholders can comment on this draft proposal by 15 October 2025. Partial enforcement will begin in December 2025, the same day the final cabinet order is promulgated. But starting in June 2026, full enforcement will take place.