Japan to Designate Chlorpyrifos, MCCPs and Long-Chain PFCAs as CSCL Class I Specified Chemical Substances

According to a Ministry of Economy, Trade and Industry (METI) notice dated 2 February 2026, the draft approach was developed jointly with the Ministry of Health, Labour and Welfare and the Ministry of the Environment. Authorities indicated that no specific derogations are planned, which means businesses should prepare for a near-total ban once the designation takes effect.

What CSCL Class I Status Means

Class I Specified Chemical Substances are subject to stringent controls because they are considered persistent, bioaccumulative and capable of long-range environmental transport. In practice, the designation typically results in a prohibition on manufacture, import and use, with only narrow exemptions such as limited research and testing activities under the CSCL framework.

For supply chains, the practical compliance question is not only whether a substance is used as a raw material, but whether it is present in mixtures and articles. CSCL controls can also trigger restrictions on importing certain products that contain the listed substances, which raises due diligence expectations for importers and downstream brands.

Chemicals and Product Categories Likely to Be Affected

Chlorpyrifos is an organophosphate insecticide, and the proposed controls are expected to affect pesticide and wood-preservative supply chains, including import restrictions for relevant treated products.

MCCPs are commonly used as plasticisers and additive flame retardants. They can also appear in metalworking fluids, lubricants, paints, adhesives, sealants and textile treatments. Companies should treat MCCPs as a high-risk input for formulation reviews, especially where chlorine content and carbon-chain criteria determine whether a material falls within the scope.

Long-chain PFCAs, including their salts and related substances, are used for water and oil repellency and surface treatments. Import bans may extend across a wide range of treated articles, including coated textiles, carpets and clothing, as well as certain uses in lubricants, paints, adhesives, waxes and fire-extinguishing agents.

Timeline and Practical Compliance Steps

Japan began public consultation on the draft Cabinet Order in January 2026, with promulgation expected in spring 2026 and enforcement anticipated for autumn 2026. That timetable leaves limited runway for complex product portfolios.

Manufacturers and importers should begin substance mapping now, obtain updated supplier declarations, and identify where these substances may enter through additives or surface treatments. Where substitution is likely, companies should prioritise reformulation pathways, qualification testing and inventory management plans to avoid stranded stock at the point the import and use restrictions take effect.

Summary

Japan’s proposed CSCL Class I designations for chlorpyrifos, MCCPs and long-chain PFCAs would introduce broad prohibitions and potential product-level import controls from autumn 2026. With no exemptions currently signalled, early supply-chain engagement and reformulation planning will be critical for compliance.