June 2026

On 19 May 2026, the Japanese Cabinet approved an amendment to the enforcement order of Japan's Chemical Substances Control Law (in Japanese), jointly announced by the Ministry of Economy, Trade and Industry, Ministry of Health, Labour and Welfare, and Ministry of the Environment. In alignment with resolutions from 12th Conference of the Parties of the Stockholm Convention (April – May 2025) to eliminate these substances globally, the amendment formally designates four groups of chemical substances as Class I Specified Chemical Substances: (i) Long-chain perfluorocarboxylic acids and their salts, (ii) Long-chain perfluorocarboxylic acids-related substances, (iii) chlorpyrifos, and (iv) Medium-Chain Chlorinated Paraffins.

Key regulatory consequences include manufacturing and import restrictions, product-specific import prohibitions, and mandatory technical handling standards for certain products.

The amendment will be promulgated on 22 May 2026 and enters into force on 22 November 2026.

The Japanese Cabinet approved an amendment to the enforcement order of Japan's Chemical Substances Control Law (in Japanese), which was jointly announced by the Ministry of Economy, Trade and Industry (METI), Ministry of Health, Labour and Welfare (MHLW), and Ministry of the Environment (MOE) on 19 May 2026.

Background:

The amendment is rooted in decisions made at the 12th Conference of the Parties (COP12) to the Stockholm Convention on Persistent Organic Pollutants (April – May 2025), which resolved to globally eliminate Long-chain perfluorocarboxylic acids (LC-PFCA) and its salts, LC-PFCA-related substances, chlorpyrifos, and Medium-Chain Chlorinated Paraffins (MCCP).

Japan's Chemical Substances Council — a joint session of the Pharmaceutical Affairs and Food Sanitation Council's Chemical Safety Subcommittee and the Central Environment Council's Environmental Health Subcommittee — reviewed the four substance groups and concluded that they satisfy all statutory criteria for Class I Specified Chemical Substances under Article 2(2) of the Chemical Substances Control Law because of their: (a) persistence in the environment; (b) high bioaccumulation potential; and (c) long-term toxicity to humans or higher predatory animals.

Key Regulatory Changes:

(1) LC-PFCA and its salts, LC-PFCA-related substances, chlorpyrifos, and MCCP are formally designated as Class I Specified Chemical Substances. This classification imposes: Government authorization required for manufacture and import (prohibited in principle); restrictions on use; and import prohibition for government-designated products containing these substances.

(2) The following product categories cannot be imported into Japan when containing the specified substances:

• Lubricating oils and equivalent products when containing LC-PFCA and its salts,

• LC-PFCA-related substances,

• MCCP;

• Wood insecticides when containing chlorpyrifos.

(3) On a provisional basis, fire extinguishers, fire extinguisher agents, and foam fire extinguishing agents, when containing LC-PFCA and its salts or LC-PFCA-related substances, must comply with government-prescribed technical standards for handling.

Transitional Measures:

Appropriate transitional measures and supplementary provisions have been incorporated to allow for a structured compliance transition.

Implementation Schedule:

Promulgation Date: 22 May 2026

Enforcement Date for Items (1)–(3): 22 November 2026 (six months after promulgation)