Reference source : e-GOV Public Comment Portal - Japan
The competent Japanese ministries have revised the technical standards and labelling requirements for certain products containing PFHxS-related substances under the Chemical Substances Control Law (CSCL). The public consultation period for both amendments ran from 31 March 2026 to 30 April 2026.
Both revisions implement Cabinet Order No. 416 of 2025, which designated perfluoro (hexane-1-sulfonic acid)-related substances" (PFHxS-related substances) as Class I Specified Chemical Substances under the CSCL.
Technical Standards and Labelling Requirements Updated
The updated technical standards and labelling requirements concern fire extinguishers, fire-extinguishing agents for fire extinguishers, and foam fire-extinguishing agents containing PFHxS-related substances.
Under the updated standards, these products are included in the list of products subject to handling requirements under Article 28(2) of the CSCL. At the same time, the labelling notice has been amended in order to extend existing display requirements to products containing PFHxS-related substances under Article 29(1) of the CSCL.
Key changes include:
Chemicals related to PFHxS have been included as Class I Specified Chemical Substances in the CSCL.
The addition of fire extinguishers, fire-extinguishing agents for fire extinguishers, and foam fire-extinguishing agents containing PFHxS-related substances to the product categories subject to technical handling standards.
Amendment of the technical standards ordinance in relation to the inclusion of PFHxS-related substances among regulated fire-extinguishing products.
Amendment of the labelling notice to require that containers, packaging, or invoices for such products display the necessary information to prevent environmental pollution.
The labelling information remains unchanged, since the requirements are the same as those currently applicable to labelling of products containing PFOS, PFOA, PFOA-related substances, or PFHxS and its salts.
The amended orders were promulgated on 12 June 2026 and entered into force on 17 June 2026.
Obligations for Stakeholders
Businesses engaged in the manufacture, import, use, distribution, or other handling of fire extinguishers, fire extinguishing substances used in fire extinguishers, or foam fire extinguishing substances in Japan should assess whether their products contain any PFHxS-related substances.
Where applicable, businesses should ensure that affected products are processed according to the new CSCL technical requirements and that containers, packages, or invoices bear the required labelling information. In addition, businesses need to verify if the new requirements apply to products already on the Japanese market by reviewing product lines, supply chain information, and documentation.
