Japan Finalises The Scope Of Long-Chain PFCA-Related Substances Under The CSCL

Japan promulgated a ministerial ordinance on 18 September 2026 defining the scope of long-chain PFCA-related substances under the Chemical Substances Control Law. The consultation result records three submissions and changes to the draft.

The underlying Class I designations had already been promulgated through Cabinet Order No 171 on 22 May 2026. The relevant controls are scheduled to commence on 22 November 2026.

Substance And Product Scope

Article 1(1)(41) of the amended Enforcement Order covers C9–C21 perfluoroalkanoic acids and their salts. Article 1(1)(42) covers specified related substances capable of generating long-chain PFCAs through natural chemical change. These are distinct legal descriptions.

Under the Class I framework, manufacture and import are prohibited in principle, subject to the statutory permission system and limited exceptions. Article 7 designates import-prohibited product categories. These include specified lubricants, treated textiles, paints, repellents, adhesives, firefighting products, waxes and professional photographic film.

Trace Impurities

The ministries’ response to comments explains the treatment of impurities. Presence may fall outside Class I controls where it poses no relevant risk through environmental pollution and has been reduced to the industrially technically and economically achievable level.

This is not a general concentration-based exemption. A declaration that a substance was not intentionally used does not, on its own, establish that the impurity conditions are met.