LC‑PFCAs Added to Japan CSCL Class I Substances List

By Yuko Howell, Regulatory Affairs Lead, Software, UL Solutions

On May 22, 2026, Japan finalized amendments to the Enforcement Order of the Chemical Substances Control Law (CSCL), formally designating several additional chemicals as Class I Specified Chemical Substances, the most stringently regulated category under CSCL. The Cabinet approved the amended order following a public consultation earlier this year, advancing Japan’s implementation of international chemical control commitments.

Newly Designated Class I Specified Chemical Substances

The amended Enforcement Order designates the following chemicals as Class I Specified Chemical Substances:

• Long-chain perfluoroalkane acids (LC PFCAs) with carbon chain lengths from C9–C21, and their salts
• LC PFCA-related substances, defined as compounds containing perfluoroalkyl groups (C8–C20) that may degrade into LC PFCAs through natural processes
• Chlorpyrifos
• Medium-chain chlorinated paraffins (MCCPs), defined as straight-chain chlorinated alkanes with carbon chain lengths C14–C17 and chlorine content of 45% or greater by weight

These substances are subject to the strictest controls under CSCL due to their persistence, bioaccumulation potential, and long-term toxicity. This designation also reflects decisions adopted at the 12th meeting of the Conference of the Parties (COP12) to the Stockholm Convention, which targets them for global elimination.

Regulatory controls under CSCL

As Class I Specified Chemical Substances, these substances are subject to the highest level of regulatory control under CSCL, including:

• Prohibition on manufacture and import, except in limited cases requiring government authorization
• Import bans on specified products containing Class I Specified Chemical Substances
• Product-specific technical standards and handling requirements for certain uses

For LC PFCAs and LC PFCA-related substances, the amended order also establishes temporary technical standards for specific products, including firefighting equipment and firefighting agents, pending further regulatory measures.

The amendment does not include essential-use exemptions, consistent with Japan’s obligations under the Stockholm Convention.

Products subject to import restrictions

The amended Enforcement Order identifies products that may not be imported if they contain Class I Specified Chemical Substances, including:

• Lubricants and related products containing LC PFCAs, LC PFCA-related substances, or MCCPs
• Wood insecticides containing Chlorpyrifos

These provisions extend CSCL compliance obligations beyond substances themselves to finished products and articles placed on the Japanese market.

Scope of LC PFCA related substances

The specific scope of LC PFCA-related substances will be defined in a joint ministerial ordinance issued by the Ministry of Health, Labour and Welfare (MHLW), the Ministry of Economy, Trade and Industry (METI), and the Ministry of the Environment (MOE), following review by a three ministry advisory committee.

According to joint council materials, LC PFCA-related substances are expected to include compounds that:

• Contain perfluoroalkyl groups with carbon chain lengths C8–C20, and
• Can degrade into LC PFCAs (C9–C21) through natural processes

The same materials indicate that the regulatory approach will follow the model used for PFOA  and PFHxS related substances, whereby:

• A broad definition is established in the Enforcement Order, and
• Specific substances are designated through ministerial ordinances, based on indicative lists and scientific assessment

Indicative list of candidate LC PFCA-related substances, including a wide range of fluorinated precursors, polymers, and derivatives, have already been proposed and will form the basis for further regulatory specification.

Publication and implementation of the ministerial ordinance is expected from fall 2026 onward, aligned with the broader enforcement timeline.

Regulatory impact

This amendment expands Japan’s Class I Specified Chemical Substances list and designates LC‑PFCAs as the fourth PFAS group regulated domestically, following PFOS, PFOA, and PFHxS.

Full enforcement of the amended requirements is to take effect on November 22, 2026, following a transitional period after promulgation.

Companies potentially affected by the amendment should evaluate supply chains, product formulations, and import portfolios to ensure compliance ahead of full enforcement.

References

• Official Gazette of Japan, May 22, 2026 (Cabinet Order No. 171) (Japanese only)
• METI / MHLW / MOE Joint Committee Materials on LC PFCA Designation (Japanese)