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Taiwan’s Ministry of Environment has announced a draft regulation to list 269 per- and polyfluoroalkyl substances (PFAS) as chemical substances of concern. The proposed rule—open for public comment until 4 September 2025—will enter into force on 1 January 2026, creating new compliance duties across manufacturing, import, and distribution sectors.
Key Insights
The regulation introduces concentration thresholds and operational controls that will apply to PFAS used across a wide range of industries, including electronics, textiles, chemicals, and consumer goods. Professionals throughout the manufacturing value chain must now assess their portfolios for affected PFAS and prepare for new labelling, reporting, and authorisation obligations.
What the Draft PFAS Regulation Proposes
Under the draft, Taiwan classifies PFAS into three categories:
- Perfluoroalkyl acids and precursors
- Polymers
- Gases
A control concentration of 0.1% applies to all listed substances. For perfluoroalkyl acids and related compounds, operations exceeding 1% concentration require official approval, monthly record-keeping, and quarterly reporting. For polymers and gases, the same obligations apply if the concentration exceeds 30%. Products below these thresholds must still carry specific labelling if above 0.1%.
Use cases related to testing, research, education, and detection are exempt from control measures.
Regulatory Context and International Alignment
The move aligns Taiwan’s chemical policy with growing international scrutiny of PFAS, often referred to as “forever chemicals” due to their persistence in the environment and bioaccumulative properties. Substances like perfluorooctanoic acid (PFOA), perfluorohexane sulfonic acid (PFHxS), and related compounds are already regulated under the Stockholm Convention, which Taiwan mirrors in its approach.
The Ministry cited both environmental protection and public health as primary drivers for expanding PFAS oversight. The proposed list of 269 substances was developed in consultation with OECD and EU REACH classifications.
What Stakeholders Must Do
Manufacturers, importers, and downstream users must now review their formulations and supply chains for listed PFAS. Early action is essential to ensure:
- Regulatory approvals are secured for operations involving threshold exceedance
- Product packaging meets new labelling requirements
- Internal tracking and documentation processes are in place by the compliance date
Industry professionals are encouraged to engage during the 30-day comment period and to coordinate with legal or regulatory specialists to assess business impact.
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