In April 2024, the Ministry of Economy, Trade and Industry (METI), the Ministry of Health, Labour and Welfare (MHLW), and the Ministry of the Environment (MOE) jointly issued the revision of the Order of Enforcement of Act on the Regulation of Manufacture and Evaluation of Chemical Substances, which is largely consistent with the draft revision published on February 1, 2024. The amendment regulates PFOA and its related compounds by categorizing them into two types: those strictly prohibited and those allowed for use within specified period and purposes. Additionally, PFOA isomers or their salts and related compounds are designated as Class I Specified Chemical Substances. Their manufacture, import, and use are prohibited except for the specified purposes and within the permitted period. The details are as follows:
| Designated as Class I Specified Chemical Substances | Permitted uses | Permitted periods |
| Perfluoro alkanoic acid (limited to those with a branched structure and 8 carbon atoms) or their salts | / | / |
| PFOA related compounds | ||
| 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecafluoro-8-iodooctane (also known as perfluorooctyl iodide) | The production of pharmaceutical products | December 31, 2036 |
| 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecan-1-ol (also known as 8:2 fluorotelomer alcohol) | The manufacture of invasive and implantable medical devices | December 3, 2025 |
| Compounds designate as pentadecafluoroalkyl groups (limited to those with 7 carbon atoms) directly bonded to a carbon atom, and generate perfluorooctanoic acid or perfluoro alkanoic acid due to a chemical change due to natural action | / | / |
Products to be banned as imports, in which PFOA isomers or their salts and PFOA related compounds are used:
| PFOA isomers or their salts | Water-resistant paper and oil-resistant paper |
| Water-repellent textiles and oil-repellent textiles | |
| Cleaning agents | |
| Anti-reflection agents used in the manufacture of semiconductors | |
| Paints and varnish | |
| Water repellent and oil repellent | |
| Adhesives and sealing fillers | |
| Fire extinguishers, fire-extinguishing agents, and fire-extinguishing foam | |
| Toners | |
| Water-resistant clothes and oil- resistant clothes | |
| Water-repellent floor coverings and oil-repellent floor coverings | |
| Floor waxes | |
| Photographic paper | |
| PFOA related compounds | Water-repellent textiles and oil-repellent textiles |
| Antifoaming agents | |
| Water repellent, oil repellent, antifouling agent and fiber protectant | |
| Optical fiber or its surface coating agents | |
| Fire extinguishers, fire-extinguishing agents, and fire-extinguishing foam | |
| Water-resistant clothes and oil- resistant clothes | |
| Water-repellent floor coverings and oil-repellent floor coverings | |
| Floor waxes |
Enforcement Dates
- Around August 2024, PFOA isomers or their salts will be officially designated as Class I Specified Chemical Substances and the ban will be implemented.
- Around December 2024, PFOA-related compounds will be designated as Class I Specified Chemical Substances and the ban will be implemented, including a prohibition on the import of products containing PFOA isomers or their salts and related compounds.
Exporters to Japan shall examine whether their products are involved in the above situations and make timely adjustments to avoid unnecessary trade losses. CIRS will continue to monitor the latest global regulations on PFOA for you.
If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.
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