A cabinet order to partially amend the Enforcement Order of the Chemical Substances Control Law has been approved and will be formally issued on December 17, 2025, according to a joint announcement made by Japan's Ministries of Health, Labour and Welfare (MHLW), Economy, Trade and Industry (METI), and Environment on December 12, 2025. Perfluorohexane Sulfonic Acid (PFHxS) and related chemicals are classified as Class I Specified Chemical chemicals under the core amendment, which also establishes appropriate control procedures.
Context
Japan has chosen to include PFHxS and related substances as Class I Specified Chemical Substances under the Chemical Substances Control Law in order to comply with the phase-out requirements for newly listed POPs and in accordance with the resolutions of the Tenth Conference of the Parties (June 2022) to the Stockholm Convention on Persistent Organic Pollutants (POPs).
Chemicals that show persistence, a high potential for bioaccumulation, and long-term toxicity to humans or higher predators are classified as Class I Specified Chemical Substances. Regulations pertaining to these chemicals include limitations on their usage, a prohibition on the import of goods identified by cabinet order, and the requirement for permits for manufacturing and import (which are, in theory, forbidden).
Overview of the Cabinet Order
(1) Class I Specified Chemical Substance Designation
Class I Specified Chemical compounds include PFHxS and similar compounds. Compounds with a (tridecafluoroalkyl)sulfonyl group (six carbon atoms only) or a [(tridecafluoroalkyl)sulfinyl]oxy group (six carbon atoms) that can undergo chemical transformations through natural processes to produce perfluorohexane sulfonic acid or perfluoroalkyl sulfonic acids are referred to as PFHxS-related substances. The Ministry of the Environment, METI, and MHLW will specify specific compounds.
(2) Ten New Product Categories Including Substances Associated with PFHxS Imports are prohibited.
· Textiles that have been treated to repel water or oil
· Metalworking etching agents
· Etching agents used in the production of semiconductors
· Electroplating surface treatment agents and their compounding additions
· Anti-reflective materials for the production of semiconductors
· Semiconductor photoresists
· Fiber protectants, oil repellents, and water repellents
· Fire extinguishers, foam fire-extinguishing agents, and fire-extinguishing agents for fire extinguishers
· Clothing that has been treated to repel oil or water
· Floor coverings with an oil or water repellent treatment
(3) Elimination of an Exempt Use
The list no longer includes the Class I Specified Chemical Substance 8:2 Fluorotelomer Alcohol's exempted use.
(4) Identification of Items Needing Adherence to Handling Guidelines
Products that must adhere to nationally specified technical standards during handling include fire extinguishers, foam fire-extinguishing agents including PFHxS-related compounds, and fire-extinguishing agents for fire extinguishers.
(5) Transitional Actions
Before this cabinet order becomes operative, MHLW, METI, and the Ministry of the Environment may consult advisory councils about the creation or modification of pertinent ministerial ordinances. Based on prior regulations, penalties for actions committed prior to its enforcement will still be applicable.
Dates of Operation
· Item (3): Commencing on December 17, 2025.
· Items (1), (2), and (4): As of June 17, 2026.
· On the date of promulgation or, if necessary, six months following promulgation, transitional measures under Item (5) and others will be put into effect.
