Japan CSCL: Japan Proposes Ban on 138 PFAS Chemicals Starting January 2025 (Consultation)

On September 9, 2024, Japan's Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment jointly issued a draft proposal to prohibit the manufacture, import, and use of 138 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) under the Chemical Substance Control Law (CSCL).

The proposal designates these PFAS compounds as Class I Specified Chemical Substances, which would effectively ban their manufacture, import, and use in Japan. This designation includes PFOA isomers, their salts, and PFOA-related compounds.

Key Points of the Proposal:

• Prohibition of Manufacture and Import: The ban will apply to PFOA isomers, their salts, and PFOA-related compounds starting January 10, 2025.
• Ban on Import of Designated Products: Products containing these substances will also be prohibited from import.
• Restriction on Use: Use of these substances will be limited to approved essential applications only.
• Technical Standards: Establishment of technical standards for handling specified products containing these substances.

The ordinance is expected to be adopted in November 2024 and will take effect on January 10, 2025.
With the public comment period now closed as of October 9, 2024, stakeholders should prepare for compliance with the upcoming regulations. Manufacturers and importers are advised to review their product portfolios and supply chains to identify any use of the soon-to-be-restricted substances.
This regulatory change aligns Japan with global efforts to restrict PFAS use and follows the country's earlier actions on related substances like PFHxS. Proactive measures will be essential to ensure compliance by the effective date.