Japan's PFHxS restriction enters into force, confirming import ban on treated products

Japan has confirmed that its restriction on PFHxS-related compounds is now legally binding. The Cabinet Order designating these substances as Class I Specified Chemical Substances under the Act on the Regulation of Manufacture and Evaluation of Chemical Substances, commonly known as the Chemical Substances Control Law, was promulgated on 17 December 2025 and entered into force on 17 June 2026. CDX first reported on this measure in February 2026, while it was still open for public consultation; see our earlier article, Japan Consults on PFHxS Restrictions Under Chemical Substances Control Law, for background on the substance list and the consultation process.

PFHxS, its salts, and related compounds are persistent organic pollutants: they resist environmental breakdown, accumulate in living organisms, and are linked to chronic toxicity. The restriction covers 117 specific PFHxS-related substances across four categories, spanning metal and ammonium salts and related sulfonamides, halides and amide derivatives, and acrylate and methacrylate copolymers. From 17 June 2026, manufacturing, importing and using any of these substances in Japan is prohibited, with limited exceptions requiring specific authorisation.

The restriction extends beyond the substances themselves to products that contain or were treated with them. Import into Japan of products such as water- and oil-repellent textiles, fire-fighting foams and extinguishing agents, semiconductor processing chemicals, and plating surface treatment agents is now banned if they contain PFHxS-related compounds, regardless of where the product was manufactured. Companies exporting these product categories to Japan need to confirm with their formulation and component suppliers that no PFHxS-related substance is present, since the ban applies at the point of import rather than only to domestic Japanese manufacturing.

This measure implements Japan's obligations under the Stockholm Convention on Persistent Organic Pollutants, following the decision at the tenth Conference of the Parties in 2022 to add PFHxS, its salts and related compounds to the Convention's list of substances for global phase-out. The EU implemented the same Stockholm Convention listing through its POPs Regulation in 2023, meaning companies already tracking PFHxS restrictions for the EU market can extend largely the same supplier due diligence process to cover the Japanese requirement, though the two frameworks differ in scope and the specific product categories subject to import restrictions.

Source: WTO TBT Notification, Addendum of 3 August 2026