Japan Amends Enforcement Order of Chemical Substances Control Law, PFHxS to be Banned from Production and Import

On December 12, 2025, Japan's Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment jointly announced that a cabinet order to partially amend the Enforcement Order of the Chemical Substances Control Law has been approved and will be officially issued on December 17, 2025. The core amendment involves designating PFHxS (Perfluorohexane Sulfonic Acid) and related substances as Class I Specified Chemical Substances and establishing corresponding control measures.

Background

Based on the resolutions of the Tenth Conference of the Parties (June 2022) to the Stockholm Convention on Persistent Organic Pollutants (POPs), and to fulfill the phase-out requirements for newly listed POPs, Japan has decided to include PFHxS and related substances as Class I Specified Chemical Substances under the Chemical Substances Control Law.

Class I Specified Chemical Substances are defined as those exhibiting persistence, high bioaccumulation potential, and long-term toxicity to humans or higher predators. For these substances, regulations include requiring permits for production and import (which are prohibited in principle), restrictions on use, and a ban on the import of products designated by cabinet order.

Outline of the Cabinet Order

(1) Designation of Class I Specified Chemical Substances

PFHxS and related substances are designated as Class I Specified Chemical Substances. PFHxS-related substances refer to compounds containing a (tridecafluoroalkyl)sulfonyl group (with six carbon atoms only) or a [(tridecafluoroalkyl)sulfinyl]oxy group (with six carbon atoms) that can be chemically transformed by natural processes to generate perfluorohexane sulfonic acid or perfluoroalkyl sulfonic acids. Specific substances will be stipulated by MHLW, METI, and the Ministry of the Environment.

(2) Addition of 10 Product Categories Containing PFHxS-related Substances Subject to Import Ban

• Fabrics treated for water or oil repellency
• Etching agents for metalworking
• Etching agents for semiconductor manufacturing
• Surface treatment agents for electroplating and their compounding additives
• Anti-reflective agents for semiconductor manufacturing
• Photoresists for semiconductors
• Water repellents, oil repellents, and fiber protectants
• Fire extinguishers, fire-extinguishing agents for fire extinguishers, and foam fire-extinguishing agents
• Clothing treated for water or oil repellency
• Floor coverings treated for water or oil repellency

(3) Removal of an Exempted Use

The exempted use for the Class I Specified Chemical Substance 8:2 Fluorotelomer Alcohol is removed from the list.

(4) Designation of Products Requiring Compliance with Handling Standards

Fire extinguishers, fire-extinguishing agents for fire extinguishers, and foam fire-extinguishing agents containing PFHxS-related substances are temporarily designated as products that must comply with nationally established technical standards during handling.

(5) Transitional Measures

MHLW, METI, and the Ministry of the Environment may seek opinions from advisory councils regarding the establishment or revision of relevant ministerial ordinances before this cabinet order takes effect. Penal provisions for actions taken before its enforcement will still apply based on previous regulations.

Effective Dates

• Item (3): Effective from December 17, 2025.
• Items (1), (2), and (4): Effective from June 17, 2026.
• Transitional measures under Item (5) and others will be implemented on the promulgation date or six months after promulgation, as appropriate.

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Further Information

MOE