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On February 25, 2025, the Foreign Environmental Cooperation Center, Ministry of Ecology and Environment (MEE-FECO) of China opened a public consultation on the indicative lists of three groups of PFAS chemicals. This initiative aims to support China in fulfilling its obligations under the Stockholm Convention on Persistent Organic Pollutants (POPs). Comments are welcome before May 19, 2025.
Background
Stockholm Convention is an international environmental treaty signed on May 22, 2001, and effective in China from November 11, 2004. So far, there are 34 POPs listed in the Annex A (Elimination), Annex B (Restriction) and Annex C (Unintentional production) of the Convention. China strictly adheres to the requirements of the Convention and has phased out the use of 23 controlled POPs, including ‘PFHxS, its salts and PFHxS-related compounds (no exemptions)’ and ‘PFOA, its salts and PFOA-related compounds (provided with specific exemptions)’.
For ‘long-chain PFCAs, their salts and related compounds’, the Persistent Organic Pollutants Review Committee (POPRC) adopted at its twentieth meeting the decision to recommend to the Conference of the Parties to consider listing this group of PFAS chemicals in Annex A to the Convention with specific exemptions. Once the listing is adopted, China will implement certain controls under the Convention.
To support the Parties in implementing controls for these PFAS chemicals, POPRC prepared three indicative lists of CAS numbers and invited the Parties to share comments. The MEE-FECO is responsible for China’s implementation of the Convention, and recently issued an official notice to collect related information on these chemicals from the domestic industry.
PFOA, its salts and PFOA-related compounds
‘PFOA, its salts and PFOA-related compounds’ were included in Annex A of the Convention in 2019. As a party to the Convention, China has introduced legislation to phase out this group of PFAS chemicals.
On 31 December 2022, China MEE released the List of New Pollutants for Priority Management (2023) in which 'PFOA, its salts and PFOA-related compounds' are listed with strict control measures with specific exemptions. To cope with the implementation of the 2023 List, China MEE released the Inventory of Severely Restricted Toxic Chemicals (2023) on October 18, 2023, adding ‘PFOA, its salts and PFOA-related compounds’. They can only be manufactured, processed/used, imported and exported for specific permitted usages.
However, no CAS numbers are provided in these two important control lists. To help enterprises ensure compliance, the Solid Waste and Chemicals Management Center of China MEE issued an Indicative List of PFOA, Its Salts and PFOA-related Compounds on November 2, 2023, including CAS numbers and HS codes for 363 related substances.
This time the consultation made public an updated indicative list presented in three tables for PFOA-related substances, and more CAS numbers are provided. You can refer to the link here to access this updated indicative list.
PFHxS, its salts and PFHxS-related compounds
In March 2022, by a MEE notice, an indicative list of ‘PFHxS, its salts and PFHxS-related compounds’ drafted by the POPRC was issued to collect relevant information in China. In June 2022, the decision on listing ‘PFHxS, its salts and PFHxS-related compounds’ in Annex A of the Convention was adopted, provided with no specific exemptions. Following the listing under the Convention, China MEE included this group of PFAS chemicals in the List of New Pollutants for Priority Management (2023) in late 2022 to impose prohibitions on their manufacture, import, export, and use.
To facilitate the prohibitions, China’s catalogues of goods prohibited from import and export were updated in June 2023 to include ‘PFHxS, its salts and PFHxS-related compounds’ (read more). On January 9, 2024, China MEE released an announcement to stress that China has comprehensively phased out ‘PFHxS, its salts and PFHxS-related compounds’.
This time the consultation made public an updated indicative list presented in two tables with more CAS numbers for PFHxS-related substances. The scope applicable to the prohibitions may be expanded in China. You can download this updated indicative list here.
Long-chain PFCAs, their salts and related compounds
‘Long-chain PFCAs, their salts and related compounds’ are expected to be included in Annex A of the Convention in 2025. As a party to this convention, China needs to pre-emptively take action to collect information on chemical activities involving these chemicals, thereby imposing reasonable regulatory controls within China in the future.
On July 20, 2023, China MEE issued a notice to call for information on their production and use information (including production quantity, use quantity, use purpose, etc.), and their substitutes or relevant substitute technologies (including the introduction of substitutes or substitute technologies, substitute costs, substitute effects, etc.). This time the consultation focuses on an indicative list for long-chain PFCAs, their salts and related compounds.
Comments can be submitted via e-mail ([email protected] or [email protected]).
