Japan’s MHLW, METI, and MoE launched a public consultation proposing new bans under the Chemical Substances Control Law (CSCL). The move targets chemicals recently added to Annex A of the Stockholm Convention for elimination.
The proposal seeks to classify the following as Class I Specified Chemical Substances, effectively prohibiting their manufacture and import:
• Chlorpyrifos (CAS 2921-88-2)
• Medium-Chain Chlorinated Paraffins (MCCPs) — C14–C17 chlorinated alkanes (≥45% chlorine)
• Long-Chain Perfluorocarboxylic Acids (PFCAs) — C9–C21, including salts and related substances
Scope of Proposed Restrictions
If adopted, the regulations will:
• Ban manufacture and import of the targeted substances in 2026
• Prohibit import of products containing these chemicals
• Establish waste-handling and disposal standards, especially for PFCA-containing firefighting foams
Key affected product categories:
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Timeline & Public Consultation
• Consultation launched: 3 October 2025
• Deadline for comments: 2 November 2025
• Expected enforcement: 2026
Submissions must be filed through Japan’s official e-Gov portal in the prescribed format.
Guidance for Industry
Companies manufacturing or importing in Japan should:
• Screen products and raw materials for chlorpyrifos, MCCPs, and long-chain PFCAs
• Develop compliance action plans for 2026
• Update supply-chain documentation and analytical testing protocols
• Monitor government notices for finalized regulatory obligations
Reference: Public Consultation on CSCL Restrictions
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