By Hitesh Ram | Thu Jul 17 2025 | 2 min read

Table of Contents

If your company manufactures, imports, or sells chemical-based products into Japan, this regulation needs to be on your radar now.

On November 15, 2024, the Japanese government officially adopted a ministerial ordinance under the Chemical Substances Control Law (CSCL) banning the manufacture, import, and use of 138 PFAS (Per- and Polyfluoroalkyl Substances). These substances have now been classified as Class I Specified Chemical Substances, meaning their use is prohibited in nearly all circumstances.

The ban takes effect on January 10, 2025, with limited exemptions and permissions defined in the ordinance (for certain medical-device and pharmaceutical uses). For all other applications, manufacture, import, and use are prohibited under the Chemical Substances Control Law (CSCL).

What Happened

  • September 9, 2024: Japan’s Ministry of Health, Labour and Welfare (MHLW), Ministry of the Environment (MOE), and Ministry of Economy, Trade and Industry (METI) issued a joint draft ordinance.
  • October 9, 2024: Public comment period ended.
  • November 15, 2024: Ministerial Ordinance No. 4 was adopted.
  • January 10, 2025: Ban becomes fully enforceable.

>Note: While the ordinance takes effect immediately, a few narrowly defined exemptions remain valid through their specific sunset dates (e.g., 8:2 FTOH for medical-device coatings → Dec 3 2025; PFOI → PFOB pharma intermediate → Dec 31 2036).

This ban applies not only to the production and import of PFAS chemicals but also to finished goods and components that contain them.

Scope of the PFAS Ban in Japan

This regulation covers:

This regulation covers:

  • Manufacturing or importing any of the 138 PFAS in Japan;
  • Using those PFAS in industrial formulations or processes; and
  • Importing designated product categories that contain them — including oil/water-treated textiles, firefighting foams, floor waxes, repellents, and optical fiber coatings. Unless specifically exempted under CSCL Article 2, manufacture, import, and use are prohibited in principle as of January 10, 2025.

What Substances Are Affected

The ban applies to 138 individual PFAS, including:

  • PFOA-related substances and salts
  • Perfluorinated carboxylic acids
  • PFAS derivatives used in coatings, fluoropolymers, electronics, batteries, and textiles

These substances have been deemed persistent, bioaccumulative, and toxic. Use in any form is considered high-risk under Japanese law.

Request the full CAS list if you need to begin supply chain screening.

Update: Japan's second PFAS ban - PFHxS (effective June 2026)

The 138-substance PFOA-related ban was not the end of Japan's PFAS action. On 12 December 2025, Japan's Cabinet approved an order designating perfluorohexane sulfonic acid (PFHxS) and related compounds as Class I Specified Chemical Substances under the CSCL, following the substance's listing for elimination at the Tenth Conference of the Parties to the Stockholm Convention in June 2022.

On 17 April 2026, Japan published the ministerial ordinance specifying 117 individual PFHxS-related substances subject to control, taking effect on 17 June 2026. From that date, the manufacture, import, and use of the 117 listed PFHxS-related substances are prohibited in principle.

Companies that previously transitioned from PFOS to alternative fluorinated chemistries may be particularly affected, as some PFOS substitutes fall within the PFHxS-related substance definition. Water-repellent and oil-repellent textiles containing PFHxS-related compounds are specifically designated as products prohibited from import. The two bans together mean that Japan now restricts PFOA-related, PFOS, and PFHxS-related substances under the same Class I framework.

What Companies Must Do Now

You have limited time to prepare. Here’s what your compliance team should be doing immediately.

1. Screen Materials and BOMs

Use chemical inventory tools or full material disclosure (FMD) methods to review all formulations, components, and packaging for any of the 138 listed PFAS.

2. Contact Suppliers

Send updated compliance surveys focused on PFAS. Request:

  • Updated declarations
  • Test reports where required
  • Phase-out commitments before Q1 2025

3. Update Internal Compliance Systems

Ensure your ERP, PLM, SDS, or chemical inventory software is updated to flag banned PFAS. Align with J-CHECK and any applicable Japan-specific registries.

4. Identify and Validate Alternatives

Collaborate with procurement and R\&D to substitute PFAS in high-risk areas such as:

  • Wire insulation
  • Battery electrolytes
  • Fluoropolymer coatings
  • Gasket or sealant materials

Japan PFAS Enforcement and Penalties

Under CSCL Article 2, PFAS are now designated as Class I Specified Chemical Substances — meaning manufacture, import, or use is banned except by ministerial permission. Import of the designated product categories containing these PFAS is likewise prohibited. Violations can trigger import bans, product seizures, and criminal penalties for responsible officers.

  • Import bans and product seizures
  • Criminal penalties for companies and responsible executives
  • Suspension of business licenses

The CSCL is fully enforceable under Japan’s environmental protection and chemical safety framework. There will be no tolerance for non-compliance.

Why This Matters Globally

This action aligns Japan with global regulatory momentum. Other frameworks already targeting PFAS include:

Manufacturers with international supply chains must now align across all these regimes simultaneously.

How Regilient Helps You Prepare for Japan’s PFAS Ban

Regilient helps manufacturers screen, collect, and verify PFAS data at scale.

With Regilient, you can:

  • Automate CAS-level PFAS screening across BOMs
  • Launch targeted supplier declaration campaigns
  • Track PFAS risks alongside REACH, RoHS, GADSL, and TSCA
  • Generate audit-ready documentation for CSCL inspections
  • Align compliance workflows with both Japanese and global regulatory systems

Whether you are a Tier 1 managing hundreds of suppliers or a smaller exporter with limited bandwidth, our platform helps ensure full PFAS traceability and mitigation before the 2025 deadline.

Contact us today to schedule a PFAS compliance diagnostic.

Topics

PFAS

Speak to Our Compliance Experts

Questions about compliance, partnerships, or support? We're here to help.

Share

Japan Bans 138 PFAS Substances Effective January 10, 2025

What did Japan ban under the CSCL PFAS ordinance?
Japan banned the manufacture, import, and use of 138 specific PFAS by classifying them as Class I Specified Chemical Substances under the Chemical Substances Control Law. Ministerial Ordinance No. 4 was adopted on 15 November 2024, and the ban became fully enforceable on 10 January 2025. Class I designation means use is prohibited in nearly all circumstances, with only narrowly defined exemptions remaining valid through their own specific sunset dates.
Does Japan's PFAS ban apply to finished products and imported components?
Yes. The ban applies not only to PFAS chemicals manufactured or imported directly, but also to finished goods and components containing the listed substances. This includes: Oil and water-treated textiles Firefighting foams Floor waxes and repellents Optical fibre coatings Unless a use is specifically exempted under CSCL Article 2, manufacture, import, and use are prohibited in principle.
Which types of PFAS are covered by Japan's 138-substance list?
The list covers PFOA-related substances and salts, perfluorinated carboxylic acids, and PFAS derivatives commonly used in coatings, fluoropolymers, electronics, batteries, and industrial textiles. These substances were classified based on persistence, bioaccumulation, and toxicity criteria under Japanese law.
Are there any exemptions under Japan's PFAS ban?
A small number of narrowly defined exemptions exist, primarily for specific medical device and pharmaceutical uses, each carrying its own fixed sunset date set out in the ordinance. Two examples cited in the original ordinance are 8:2 FTOH used in medical device coatings, exempted through December 2025, and a PFOI to PFOB pharmaceutical intermediate use, exempted through December 2036. These exemptions are use-specific and do not extend to other applications of the same substances.
What penalties apply for violating Japan's PFAS ban?
Violations of the CSCL PFAS ban can result in import bans, product seizures, suspension of business licenses, and criminal penalties for both companies and the individual executives responsible. Japan's chemical safety enforcement framework applies these penalties without tolerance for non-compliance, making this a materially different enforcement posture than a documentation-only regulatory regime.
How does Regilient help manufacturers manage Japan PFAS compliance?
Regilient's agentic sustainability platform supports compliance with Japan's CSCL PFAS ban through: CAS-level PFAS screening automated across the full bill of materials Targeted supplier declaration campaigns focused specifically on the 138 restricted substances Unified tracking of PFAS risk alongside REACH, RoHS, GADSL, and TSCA obligations Audit-ready documentation generation aligned to CSCL inspection requirements Workflow alignment across Japanese and other global PFAS regimes so the same supplier data supports multiple jurisdictions For manufacturers who have not yet completed a full PFAS screening against this list, the compliance gap is now a live enforcement risk rather than an upcoming deadline.