Japan Bans 138 PFAS Substances Effective January 10, 2025

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

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:

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.

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:

EU PFAS Restriction Proposal (under REACH)
U.S. TSCA Section 8(a)(7) PFAS Reporting Rule
Canadian CEPA Section 71 PFAS Survey
Stockholm Convention on POPs

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

How Acquis Helps You Prepare for Japan’s PFAS Ban

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

With Acquis, 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.