Japan Moves to Restrict Chlorpyrifos, MCCPs, LC-PFCAs

By Yuko Howell, Regulatory Affairs Lead, Supply Chain Team, UL Solutions

On Oct. 3, 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment (MOE) have jointly announced a draft proposal to designate three chemical groups as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL). The proposal follows the decision at the 12th Conference of the Parties (COP12) to the Stockholm Convention in May 2025 to add these substances to Annex A (Elimination).

The substances targeted for designation include:

• Chlorpyrifos (O,O-Diethyl O-(3,5,6-trichloro-2-pyridyl) phosphorothioate)
• Medium-Chain Chlorinated Paraffins (MCCPs), defined as:

1. Substances or mixtures that contain straight-chain chlorinated alkanes (C14-17) and a chlorine content of 45% or more by weight;
2. Substances or mixtures that contain straight-chain chlorinated alkanes with the following molecular formulas:
   • C₁₄H_(30−y)Cl_y (y ≥ 5)
   • C₁₅H_(32−y)Cl_y (y ≥ 5)
   • C₁₆H_(34−y)Cl_y (y ≥ 6)
   • C₁₇H_(36−y)Cl_y (y ≥ 6)

      Or substances that meet both (1) and (2).

• Perfluoroalkanoic acids (C9-21) (also known as Long-chain PFCAs) and their salts, and Perfluoroalkanoic acid-related substances (compounds that contain a perfluoroalkyl group (C8-20) directly bonded to atoms other than fluorine, chlorine, or bromine, and that, through natural chemical processes, generate Perfluoroalkanoic acids (C9-21).

Background

The Stockholm Convention targets persistent organic pollutants (POPs) that are non-biodegradable, bioaccumulative, toxic, can be transported long distances in the environment, and cause harmful effects. The inclusion of these substances in Annex A reflects global consensus on the need for their elimination.

Proposed Measures under CSCL

The Japanese government proposes the following regulatory actions:

1. Designation as Class I Specified Chemical Substances

   These substances will require government approval for manufacture and import, which will be prohibited in principle.

2. Import Ban on Products Containing the Substances

   Products containing chlorpyrifos, such as wood preservatives, will be prohibited from import.

Products containing MCCPs will also be subject to import prohibition. Affected categories include plasticizers, flame-retardant additives, industrial oils, paints, fillers for adhesives and sealants, and textile protectants.

Additionally, products containing LC-PFCAs and their salts will be banned. These include photographic films, lubricants, paints, repellents, adhesives, fire extinguishing agents, waxes, and treated textiles, clothing, and carpets.

3. Ban on Use Without Essential-Use Exemptions

   Use of these substances will be prohibited entirely, with no essential-use exemptions planned under the current proposal.

4. Technical Standards for Handling

   Products containing LC-PFCAs, their salts and related substances used in firefighting (e.g., extinguishers and foams) will be subject to handling standards.

Planned regulatory developments

The Japanese government has opened a public comment period from October 3 to November 1, 2025, inviting feedback from stakeholders including industry, academia, and environmental groups.

Following public consultation:

• Japan will notify the World Trade Organization (WTO) of the proposed changes.
• A draft amendment to the Enforcement Order is expected to be published for additional public comments in late 2025.
• Full enforcement is expected in 2026.

In parallel, MHLW, METI, and MOE will continue discussions to define and publish a list of LC-PFCA-related substances—compounds that degrade into LC-PFCAs—through ministerial ordinances beyond 2026.

References

• Draft Measures Concerning Chlorpyrifos, MCCPs, and LC-PFCAs under CSCL (Japanese only)
• Public Comment Submission Portal (Japanese only)
• MHLW/METI/MOE Chemical Substances Council – Safety Measures Subcommittee, 2nd Meeting Document (Japanese only)