On February 2, 2026, Japan’s Ministry of Economy, Trade and Industry (METI) released a notice announcing its decision to classify three substances as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL). The substances concerned are chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids (long-chain PFCAs), including their salts and related compounds. The implementation timeline was also published.
During the 12th Conference of the Parties (COP12) to the Stockholm Convention, held between April and May 2025, chlorpyrifos, MCCPs, and long-chain PFCAs and their associated compounds were added to Annex A (Elimination). Following this international decision, Japan’s Council on Chemical Substances resolved in June 2025 to designate these chemicals as Class I Specified Chemical Substances under the CSCL.
At a subsequent Council meeting in September 2025, it was confirmed that the manufacture, import, and use of these substances would be banned, with the only exception being limited use for testing and research. No specific exemptions will be introduced. The Council also clarified the product categories subject to the import prohibition and defined the range of products that must comply with applicable technical requirements.
In line with these determinations, formal promulgation and enforcement will proceed after completing the necessary administrative steps, including a public consultation on the proposed amendment to the relevant Cabinet Order.
Future Timeline
The Cabinet Order amendment designating these substances as Class I Specified Chemical Substances, along with the related import restrictions, is anticipated to come into force around autumn 2026. Businesses currently handling these chemicals are encouraged to begin assessing substitutes and preparing transition plans. The provisional schedule is outlined below:
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After January 2026: Public consultation on the draft partial revision of the CSCL Enforcement Order.
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Around Spring 2026: Promulgation of the revised Cabinet Order; a joint meeting of MHLW, METI, and MOE to discuss designation issues concerning long-chain PFCA-related substances.
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After Summer 2026: Issuance of the Ministerial Ordinance on the designation of long-chain PFCA-related substances.
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Around Autumn 2026: Enforcement of the amended Cabinet Order and the Ministerial Ordinance regarding long-chain PFCA-related substances.
Once chlorpyrifos, MCCPs, and long-chain PFCAs are formally designated as Class I Specified Chemical Substances, their manufacture, import, and use will be broadly prohibited, except for narrowly defined exceptional purposes. This restriction will also apply to companies that use these chemicals as feedstocks in the production of other substances or products.
Substances Proposed for Designation as Specified Chemical Substances and Products Subject to Import Ban:
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Substances Proposed as Class I Specified Chemical Substances |
Products Subject to Import Ban |
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Chlorpyrifos (O,O-diethyl O-(3,5,6-trichloro-2-pyridyl) phosphorothioate) |
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Medium-Chain Chlorinated Paraffins (including substances or mixtures meeting condition (1) and/or (2) below): (1) Substances or mixtures containing linear chlorinated alkanes with a carbon chain length of 14-17 and a chlorine content ≥ 45% by weight. (2) Substances or mixtures containing linear chlorinated alkanes with a carbon chain length of 14-17 conforming to the following molecular formulas: C₁₄H₍₃₀₋ᵧ₎Clᵧ （y ≥ 5） C₁₅H₍₃₂₋ᵧ₎Clᵧ （y ≥ 5） C₁₆H₍₃₄₋ᵧ₎Clᵧ （y ≥ 6） C₁₇H₍₃₆₋ᵧ₎Clᵧ （y ≥ 6） |
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Perfluoroalkyl carboxylic acids (limited to compounds with 9-21 carbon atoms) (alias: long-chain PFCAs) and their salts, as well as long-chain PFCA-related substances (referring to compounds possessing a perfluoroalkyl group (limited to groups with 8-20 carbon atoms) directly attached to an atom other than fluorine, chlorine, or bromine, and which are chemical substances capable of transforming via natural processes to generate perfluoroalkyl carboxylic acids (limited to compounds with 9-21 carbon atoms), as specified by ordinances of the Ministry of Health, Labour and Welfare, the Ministry of Economy, Trade and Industry, and the Ministry of the Environment). |
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