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

On 16 September 2025, Japan released a draft Cabinet Order proposing amendments to the Enforcement Order of the Chemical Substances Control Law (CSCL). If adopted, this change would align with the decision at the 10th Conference of the Parties (COP10) to the Stockholm Convention on Persistent Organic Pollutants in June 2022 to eliminate Perfluorohexane sulfonic acid (PFHxS)-related substances.

The draft, developed by the Ministry of Health, Labour and Welfare (MHLW), the Ministry of Economy, Trade and Industry (METI), and the Ministry of the Environment (MoE), proposes that PFHxS-related chemicals be designated as Class I Specified Chemical Substances under CSCL. This status would impose bans on their manufacture, import, and use, as well as the import of products containing them.

Previous update in August 2024

On 1 August 2024, MHLW, METI and MoE jointly released an earlier draft to designate PFHxS-related substances as Class I Specified Chemicals under CSCL. That version also included import bans on the products containing PFHxS-related substances. More information can be found here.

Key Proposals in the New 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 and labelling rules updated accordingly.
• Transitional provisions included.

Obligations for Stakeholders

Once the final Cabinet Order is adopted, manufacture, import, and use, a of PFHxS-related substances, and the import of products containing them, will be prohibited.

Stakeholders are expected to identify safer alternatives to PFHxS or apply for a specific permit to continue their activities.

Comment Period and Enforcement Dates

The public comment period is open until 15 October 2025. According to the draft, partial enforcement is planned for December 2025, coinciding with the promulgation of the Cabinet Order, while full enforcement will follow in June 2026.