Japan to Ban PFOA Isomers, Their Salts and PFOA-related Compounds

Editor's Note: According to the Gazette on July 10, 2024, Japan has revised the Enforcement Ordinance of the Chemical Substance Control Law (CSCL) to implement a phased-in ban on PFOA isomers, their salts and PFOA-related compounds. Compared to the draft proposal, the products prohibited from import have been greatly adjusted. Click here to view the latest updates.

On February 1, 2024, the Japanese Ministry of Health, Labour and Welfare (MHLW), Ministry of Economy, Trade and Industry (METI), and Ministry of Environment (MoE) issued a joint consultation regarding the designation of PFOA isomers, their salts and PFOA-related compounds as Class I Specified Chemical Substances controlled under the Chemical Substance Control Law (CSCL).

Once designated as Class I Specified Chemical Substances, their manufacture, import and use would be prohibited in principle, except for "essential uses". As proposed, two essential uses that cannot be replaced temporarily and are considered not harmful to the environment will be exempted, including:

using PFOI to produce PFOB for pharmaceutical manufacturing purpose;
using 8:2FTOH to produce PFMA for invasive and implantable medical device manufacturing purposes.

In addition, importing certain products (see table below) containing these substances will also be prohibited.

Substances	Products to be prohibited from importation
PFOA isomers and their salts	Floor wax Water- and oil-repellent fibre Water- and oil-repellent clothes Water- and oil-repellent carpet Adhesives and sealing fillers Coating agents Paints and varnish Printer toner Cleaning agents Photographic paper Water- and oil-repellent paper Anti-reflection agent used in the manufacture of semiconductors Fire extinguishers, extinguishing agents for fire extinguishers and foam extinguishing agents
PFOA-related compounds	Textile protectant and antifouling agent Water repellent and oil repellent Water- and oil-repellent textile Defoamer Coating agent for optical fibre or its surface Fire extinguishers, extinguishing agents for fire extinguishers and foam extinguishing agents

The fire extinguishers, fire-extinguishing agents used in fire extinguishers and foam fire-extinguishing agents that use these substances will be required to comply with corresponding national technical standards.

Japan has listed PFOA and its salts in the List of Class I Specified Chemical Substances in 2021 via the partial revision to the CSCL Enforcement Ordinance. The upcoming designation of PFOA isomers, their salts and PFOA-related compounds can be regarded as a supplement to the previous designation.

Due to the large number of PFOA-related compounds, the ministries are still sorting out the list of substances. The substances list drafted in 2023 can be accessed here for reference.