Japan Amends CSCL to Ban PFHxS Production and Imports

Japan has officially amended the Enforcement Order of the Chemical Substances Control Law (CSCL) to strengthen regulatory controls on perfluorohexane sulfonic acid (PFHxS) and PFHxS-related substances. The amendment was approved by the Japanese Cabinet on 12 December 2025 and announced by the Ministry of the Environment (MoE).

The revised Enforcement Order will be promulgated on 17 December 2025, marking a significant step in Japan’s efforts to tighten controls on persistent and hazardous chemicals.

Alignment with International POPs Obligations

The amendment implements Japan’s obligations under the Stockholm Convention on Persistent Organic Pollutants (POPs). PFHxS, its salts, and related substances were added to the Convention’s elimination list due to their high persistence, bioaccumulation, and long-term environmental and human health risks.

By revising the CSCL Enforcement Order, Japan is harmonizing its domestic chemical control framework with international POPs management requirements.

PFHxS Designated as Class I Specified Chemical Substances

Under the amended Enforcement Order, PFHxS-related substances will be designated as Class I Specified Chemical Substances under the CSCL, the strictest regulatory category.

This designation results in:

• A general prohibition on the manufacture and import of PFHxS-related substances
• Severe restrictions on use, subject to limited exceptions
• Additional regulatory controls on products treated with PFHxS-related substances

Import Ban on PFHxS-Containing Products

The amendment also introduces import prohibitions for specific products containing PFHxS-related substances. Ten categories of treated products are subject to the ban, including:

• Water- and oil-repellent textiles and apparel
• Metal surface-treatment and etching agents
• Semiconductor etching agents and photoresists
• Water- and oil-repellent coatings and additives
• Fire-extinguishing agents and foams

These measures aim to prevent PFHxS from entering Japan through imported finished or treated goods.

Removal of Previously Allowed Exceptional Uses

The revised Enforcement Order removes certain exceptional uses that had previously been permitted for Class I Specified Chemical Substances. This includes the withdrawal of allowed uses for 8:2 fluorotelomer alcohols, which are structurally related to PFHxS.

As a result, previously permitted applications will no longer be allowed following the amendment.

Implementation Timeline

The regulatory changes will take effect in stages:

• Removal of exceptional uses: Effective upon promulgation on 17 December 2025
• Designation of PFHxS-related substances and import bans on treated products: Effective six months after promulgation, around 17 June 2026

Further enforcement details will be clarified through related ministerial ordinances.

Implications for Industry

Companies involved in the manufacture, import, or supply of PFHxS-related substances or treated products should begin compliance preparations, including:

• Reviewing chemical inventories and formulations
• Identifying PFHxS-related substances in supply chains
• Planning product phase-outs before mid-2026
• Monitoring upcoming ministerial guidance for detailed compliance requirements

Early action will help mitigate regulatory and supply-chain risks.

Regulatory Outlook

Japan’s amendment to the CSCL Enforcement Order signals a continued move toward stricter PFAS regulation and stronger chemical risk management. As additional implementing regulations are released, companies operating in or exporting to Japan should remain vigilant and align compliance strategies with the evolving regulatory framework.
Source: Japan Bans PFHxS Chemicals