Japan has proposed amendments to its Chemical Substances Control Law (CSCL) to designate chlorpyrifos, long-chain PFAS, and MCCPs as Class I Specified Chemical Substances. This classification introduces the strictest level of control, effectively prohibiting manufacture, import, and use, aligning with global obligations under the Stockholm Convention on Persistent Organic Pollutants (POPs).

Key Regulatory Developments

On 20 March 2026, Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment (MOE) issued a draft Cabinet Order to amend the CSCL Enforcement Order.

The proposal includes designation of the following substances as Class I Specified Chemical Substances:

  • Chlorpyrifos (organophosphate pesticide)
  • Long-chain perfluorocarboxylic acids (LC-PFCAs, C9–21) and their salts
  • LC-PFCA-related substances (precursors degrading into PFCAs)
  • Medium-chain chlorinated paraffins (MCCPs, C14–17, ≥45% chlorine)

These substances are identified as persistent, bioaccumulative, and toxic, meeting the criteria for the highest restriction category under CSCL.

Regulatory Impact (Class I Designation)

Once designated, the substances will be subject to stringent controls:

  • Prohibition of manufacture and import (except limited authorized uses)
  • Ban on use and distribution in most applications
  • Import restrictions on products containing these substances
  • Potential technical standards and labeling requirements for specific PFAS-related uses

This represents a full lifecycle restriction, covering both substances and articles containing them.

Scope & Thresholds

  • No tonnage-based thresholds — restrictions apply regardless of volume

Defined substance scope includes:

  • PFAS: C9–21 carbon chain (with precursors C8–20)
  • MCCPs: C14–17 with ≥45% chlorine content
  • Trigger is based on substance identity and classification, not concentration thresholds

This reflects a hazard-based regulatory approach, consistent with POP elimination measures.

Products Affected (Import Prohibition Examples)

The proposal explicitly lists product categories subject to import bans, including:

  • PFAS-related products: Water/oil-repellent textiles, coatings, adhesives, fire-fighting foams
  • Chlorpyrifos: Wood preservatives and insecticides
  • MCCPs: Lubricants, plasticizers, flame retardants, coatings, sealants

This significantly expands compliance obligations beyond chemical substances to finished goods and articles.

Who is Affected?

  • Chemical manufacturers and importers in Japan
  • Exporters supplying chemicals or products into Japan
  • Downstream industries (electronics, automotive, textiles, coatings, plastics)
  • Supply chain actors handling PFAS, pesticides, or industrial additives

Timeline & Consultation

  • Public Comment Period: 20 March 2026 – 18 April 2026
  • Expected Adoption: Around May 2026
  • Full Enforcement: Around November 2026

Compliance Implications

Companies will need to:

  • Identify presence of listed substances in products and supply chains
  • Reformulate products or substitute restricted chemicals
  • Ensure compliance with import bans for affected product categories
  • Update regulatory documentation and chemical inventories
  • Failure to comply may result in market access restrictions and enforcement actions.

Japan’s proposal to designate chlorpyrifos, PFAS, and MCCPs as Class I Specified Chemical Substances marks a significant tightening of chemical regulations. With no thresholds and broad product coverage, the update aligns with global POP elimination efforts and signals increasing regulatory pressure on persistent and hazardous chemicals.

Source: View Official New Mexico PFAS Rule (March 2026 COMMS)

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