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Policy Watch

MHLW Drafts Triennial PFOS and PFOA Testing Rule for Building Water Supplies

Owners of specified buildings in Japan would face a new triennial test for PFOS and PFOA in drinking-water supplies if a draft health-ministry ordinance, open for comment until October 15, takes effect as planned in May 2027.

Sep 16, 20262 min read
A technician fills a glass sample vial from a rooftop water tank valve to test a commercial building's drinking water supply.

Japan's Ministry of Health, Labour and Welfare opened a monthlong public comment period on September 16 for a draft rule that would add PFOS and PFOA to the periodic water-quality checks required at what the law defines as "specified buildings".

The draft amends the enforcement rules of the Act on Securing Sanitary Environments in Buildings, which already obliges anyone with authority over a "specified building" to supply water meeting ministerial water-quality standards wherever water-supply equipment is installed to provide water for drinking and similar uses. The trigger is a separate move by the Ministry of the Environment, whose Reiwa 7 ordinance (No. 19) set the first drinking-water quality standards for PFOS and PFOA. The health ministry's draft folds those same two substances into Article 4, Paragraph 1, Item 4, Subitem D of the building rules, making them subject to testing once every three years.

Draft PFOS/PFOA testing rule: key dates
Dates as stated in MHLW's draft ordinance overview and comment notice; the ordinance is not yet final.
MilestoneDate
Public comment opensSeptember 16, 2026
Public comment closesOctober 15, 2026
Planned promulgationNovember 2026
Planned effective dateMay 2027

The ministry plans to promulgate the finished ordinance in November 2026 and bring it into force in May 2027, six months later. Comments are due by October 15, arriving via the e-Gov portal, email or post; the ministry accepts submissions only in Japanese and will not respond to each one individually. The stated legal basis is Article 2, Item 2(a) of the 1970 Cabinet Order implementing the building sanitation law.

What the draft does not settle, at least in the excerpt reviewed, is which detection method or reporting threshold laboratories must use once the every-three-year testing requirement takes effect. Those with authority over specified buildings have until mid-October to weigh in before the rule is finalized.