Taiwan Tightens Control on Toxic and Concerned Chemicals, Targeting PFAS, NP, NPEO, and Cybutryne

On May 13, 2025, Taiwan's Ministry of the Environment published the revised Categories and Management of Handling for Toxic Chemical Substances and Categories and Management of Handling for Concerned Chemical Substances in the Gazette. The amendments took effect immediately, except for provisions with designated effective dates.

The amendments specifically involves perfluorooctane sulfonic acid (PFOS),its salts and PFOS-related compounds, perfluorooctanoic acid (PFOA),its salts and PFOA-related compounds, nonylphenol (NP), nonylphenol polyethylene glycol ether (NPEO) and cybutryne. The updates are summarized as below:

NP, and NPEO

NP and NPEO are recognized for their endocrine-disrupting properties. 12 CAS numbers for NP, and 28 CAS numbers for NPEO are newly based on EU REACH and the US TSCA. The Ministry is now tightening regulations:

• Tighten the control concentration standard (w/w %) for NP and NPEO from 5 to 0.1, in accordance with Entry 46 of the Restriction List under EU REACH (Annex XVII);

• Update toxicity classification: NP from Class 1 to Class 1,3,4; NPEO from Class 1 to Class 1,4

• Update the prohibited operations and permitted uses (details can be found in Appendix 2 of Point 2,  and Appendix 3 of Point 3 of the Categories and Management of Handling for Toxic Chemical Substances).

PFOS, its salts and PFOS-related compounds

Five PFOS salts and PFOS-related compounds are newly listed as Class 1,2,4 toxic chemical substances, including:

In addition, the original toxicity classification for PFOS, Potassium perfluorooctane sulfonate, and Perfluorooctane sulfonyl fluoride are updated to Class 1, 2,4.  

These substances can only be used for research, testing, and education, and in closed systems for hard metal plating.

PFOA, its salts and PFOA-related compounds

352 chemicals that are added in the group of PFOA salts and PFOA-related compounds in Appendix 1 Table 3 of the of the Categories and Management of Handling for Toxic Chemical Substances, with their English names, CAS numbers, and structural formulas. These substances can only be used for:

1. Research, testing, and education;

2. Photolithography or etching processes in semiconductors;

3. Manufacturing of photographic film coatings;

4. Production of oil- and water-repellent textiles for labor use;

5. Manufacturing of PTFE and PVDF for industrial heat exchangers and seals;

6. Production of FEP for high-pressure wires and cables; and

7. Manufacturing of circular rings, triangular belts, and plastic parts for automotive interiors.

PFAS exemptions

It is important to note that the regulation provides clarification on the control limits for regulated PFASs. Substances or mixtures containing PFASs, which comply with the following provisions and are not intentionally added, are not subject to regulation under the Toxic and Concerned Chemical Substances Control Act (TCCSCA).

• The total concentration of PFOS, its salts and PFOS-related compounds does not exceed 10mg/kg. 

• The concentration of PFOA and its salts does not exceed 0.025mg/kg.

• The concentration of PFOA-related compounds does not exceed 1mg/kg.

• The concentration of PFHxS or its salts does not exceed 0.025mg/kg. 

• The total concentration of PFHxS-related compounds does not exceed 1mg/kg.

Transitional Measures for Toxic Substances

The Ministry provides existing operators that have handled the related toxic substances with a buffer period of 18 months to 2 years to comply with licensing, registration, pre-approval, handling quantity recording, emergency response, labeling, SDS requirements, and personnel management, and encourages the search for alternative substances to minimize health and environmental impacts.

Cybutryne

Cybutryne is the common name for N'-tert-butyl-N-cyclopropyl-6-(methylthio)-1,3,5-triazine-2,4-diamine (CAS number 28159-98-0). Due to its bioaccumulation potential and clear toxicological properties, it is designated as a concerned chemical, with a ban on its use in in the production of antifouling paints, antifouling systems, and biocides. It can only be allowed to use by academic, inspection institutions and military authorities for experimental, research, educational, testing and military purposes. Detail compliance requirements by the stipulated deadlines:

• From June 1, 2025, it will be mandatory to maintain operational records and report monthly.

• By December 1, 2026, stakeholders must ensure that all containers, packaging, operational sites, and facilities are properly labeled and accompanied by safety data sheets.

• By December 1, 2026, activities related to the manufacture, import, sale, use, and storage of cybutryne must obtain approval documents.