Singapore’s National Environment Agency (NEA) issued Circular Ref. NEA/HS/6.6/SC03 on 6 November 2026, establishing application-specific exemptions from the planned elimination of medium-chain chlorinated paraffins (MCCPs) and long-chain perfluorocarboxylic acids (LC-PFCAs). The general prohibition on the manufacture, import, export and use of these substances and products containing them remains scheduled to apply from 16 December 2026.

The measure covers MCCPs with carbon-chain lengths from C14 to C17 and chlorination levels of at least 45% by weight. It also applies to C9–C21 LC-PFCAs, their salts and related compounds. The controls implement Singapore’s obligations under the Stockholm Convention on Persistent Organic Pollutants.

What the Circular Introduces

NEA developed the exemptions following feedback that technically viable alternatives are not yet available for certain essential applications. Uses that satisfy the conditions in Annex I of the circular will be exempt from the elimination requirement and the hazardous-substance licensing requirements arising from these controls.

The exemptions are application-specific and will be reviewed as alternatives become available. Companies cannot rely solely on the industry or product category when claiming an exemption; they must confirm that the product’s composition and intended use correspond to the conditions in Annex I.

The circular also refers to chlorpyrifos because it forms part of the broader December 2026 phase-out. However, the newly announced exemptions concern MCCPs and LC-PFCAs rather than chlorpyrifos.

MCCP Exemptions

Permitted MCCP applications include specified adhesives and sealants used in aerospace, defence, waterproofing and anticorrosion applications. Exemptions also cover finished electrical and electronic equipment, associated components and auxiliary materials, flexible elastomeric thermal-insulation foam, and certain flexible-PVC applications.

Medical devices falling within the applicable statutory scope are covered, as are specified wires and cables used in medical and in-vitro diagnostic devices. Other exemptions apply to semiconductor products and manufacturing equipment, certain replacement parts and tapes used for non-structural bonding in aerospace and defence products.

The exemption for metalworking fluids is limited to professional or industrial heavy-duty processes using collection systems. Examples identified by NEA include deep drawing, broaching, precision metalworking, tapping, cold drawing, cold rolling, stamping, forging and grinding. It should not be interpreted as a general exemption for every lubricant or metalworking formulation.

LC-PFCA Exemptions

LC-PFCA exemptions are narrower. They cover replacement parts for land-based motor vehicles that have ceased mass production and semiconductors designed for replacement parts that are no longer mass-produced.

Importers and manufacturers should document the production status of the original vehicle or component and the function of the replacement part. The source does not establish a general semiconductor or automotive exemption.

Customs and TradeNet Requirements

The circular provides official HS and product codes for chlorpyrifos, MCCPs and LC-PFCAs. Traders must use the applicable codes in TradeNet import and export declarations, and the circular states that relevant permit applications are subject to approval by NEA’s Chemical Control and Management Department.

Businesses relying on an exemption should therefore retain evidence of chemical identity, concentration, product function and end use. They should also confirm the applicable declaration process before shipment rather than treating an exemption from elimination as a blanket customs exemption.

Industry Impact

The development is relevant to chemical formulators, coatings and sealant manufacturers, metalworking-fluid suppliers, electronics and semiconductor businesses, medical-device companies, automotive suppliers, importers and distributors.

Companies should reassess Singapore-bound products previously scheduled for complete phase-out. Where an exemption may apply, the supporting technical and supply-chain evidence should be recorded before 16 December 2026. Products falling outside Annex I remain subject to the general elimination date.