Six Japanese ministries, led jointly by the Fire and Disaster Management Agency, the health, trade, transport, environment and defense ministries, opened a public comment period on September 1 for a draft amendment that would extend an existing chemical-handling rule to a newly restricted class of PFAS compounds used in fire extinguishers and firefighting foam.
The rule in question sits under Article 28, Paragraph 2 of the Chemical Substances Control Law, which requires permitted manufacturers and those who use or otherwise handle a Class I Specified Chemical Substance in the course of business to follow technical standards set by ministerial ordinance whenever that substance shows up in a fire extinguisher, extinguishing agent, or foam extinguishing agent. Until now, that standard covered PFOS and its salts, PFOA and its isomers or salts, PFOA-related substances, PFHxS and its isomers or salts, and perfluorohexane sulfonic acid-related substances.
The trigger is Cabinet Order No. 171 of 2026, which will newly designate long-chain perfluoroalkane acids or their salts, and long-chain perfluoroalkane acid-related substances, as Class I Specified Chemical Substances when it takes effect on November 22, 2026.
That Cabinet Order also adds fire extinguishers, extinguishing agents, and foam agents containing the newly designated substances to the product list in the order's supplementary provisions, which is what triggers this ministerial ordinance amendment. The draft text inserts the two new substance categories into the ordinance's own definition of a regulated "contaminant," so the existing technical handling standard extends to cover them too.
| Status | Substances covered |
|---|---|
| Already regulated | PFOS or its salts; PFOA or its isomers/salts; PFOA-related substances; PFHxS or its isomers/salts; perfluorohexane sulfonic acid-related substances |
| Newly added by this amendment | Long-chain perfluoroalkane acids or their salts; long-chain perfluoroalkane acid-related substances |
The ministries plan to promulgate the amendment in early November 2026 and bring it into force on November 22, 2026, the date the underlying Cabinet Order itself takes effect. That gives manufacturers, importers, and users of PFAS-based extinguishing products a firm date to have handling practices aligned with the expanded standard.
Public comments are open from September 1 to September 30, 2026, with mailed submissions accepted if postmarked by the closing date. Submissions go through the e-Gov online form, by post, or by email to the Environment Ministry's chemical substances safety division, and the ministries will only accept comments written in Japanese; phone calls and anonymous submissions are excluded.
The filing (case number 195260054, filed under the environmental conservation category) is procedural at this stage: a proposal open for comment, not a finalized rule. The supplied excerpts do not specify penalties for noncompliance, transition allowances for existing stock, or the estimated number of businesses affected.