Japan Lists 138 PFOA-Related Compounds as Class I Specified Chemicals

Editor's Note: This article was originally published in September 2024 to analyze the draft proposal to control 138 PFOA-related compounds, and was updated on November 15, 2024 to introduce the finalized version.

On November 15, 2024, Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of the Environment (MOE) jointly issued the Ministerial Order No. 4 of 2024, designating 138 PFOA-related compounds as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL). These compounds are listed as Item No. 35 on the Class I Specified Chemical Substances List and will come into effect on January 10, 2025.

For more details, you can access the official Japanese Government Gazette here.

Proposed draft in September 2024

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 (MOE) jointly released a public consultation to introduce a new ordinance. This ordinance will designate 138 PFOA-related compounds as Class I Specified Chemical Substances under the Chemical Substances Control Law (CSCL).

Previously, on July 10, 2024, Japan amended the Enforcement Ordinance of the CSCL to designate PFOA isomers, their salts, and related compounds as Class I Specified Chemical Substances (CL news). At that time, due to the extensive number of PFOA-related compounds, only two specific chemicals were identified: perfluorooctyl iodide (CAS 507-63-1) and 8:2 fluorotelomer alcohol (CAS 678-39-7). Additional designations would be specified through subordinate ordinances.

If approved, the new ordinance will carry the same legal weight as the provisions directly included in the CSCL Enforcement Ordinance, ensuring equivalent compliance obligations. As a result, the total number of PFOA-related compounds will amount to 140, comprising:

2 substances from the CSCL Enforcement Ordinance
138 substances from the new ordinance

The new ordinance is scheduled for official publication in November 2024, with an effective date of January 10, 2025, which coincides with the effective date for PFOA-related compounds stipulated in the CSCL Enforcement Ordinance.

This designation underscores Japan's commitment to tackling the challenges associated with per- and polyfluoroalkyl substances (PFAS), forming part of the country’s ongoing initiatives to improve chemical safety and environmental protection.