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2025-11-24

NEA newsletter-202511

Latest Progress in Environmental Protection Laws and Regulations, Product Recall Case, and Experts Q&A

Japan to Designate MCCPs and LC-PFCAs as Class I Specified Chemical Substance
On October 3, 2025, Japan's MHLW, METI, and MOE jointly proposed designating Medium-Chain Chlorinated Paraffins (MCCPs) and Long-Chain Perfluoroalkanoic Acids (LC-PFCAs) as Class I Specified Chemical Substance under the CSCL. Manufacturing and import will be principally prohibited, and products containing these substances (e.g., wood preservatives, paints, textiles) will be banned from import. No exemptions for essential uses are currently planned. Public comments are open until November 1, 2025, with full enforcement expected in 2026, aligning with global POPs elimination efforts under the Stockholm Convention.

REACH Regulates PFAS in Firefighting Foams from 2030
On October 3, 2025, the EU issued Regulation (EU) 2025/1988, amending REACH Annex XVII with Entry 82 to control PFAS in firefighting foams, taking effect on October 23. The core requirement bans selling and using foams with total PFAS concentration ≥ 1 mg/L as of October 23, 2030, specifying exemptions for certain substances and phased transitions, with some extended to 2035. From October 23, 2026, relevant products must bear warning labels and be covered by management plans.

Dodecamethylpentasiloxane Withdrawn from SVHC Identification Process
The European Chemicals Agency (ECHA) has officially withdrawn Dodecamethylpentasiloxane (CAS No. 141-63-9) from its Registry of Intention for Substances of Very High Concern (SVHC) under the REACH regulation.
The substance was originally proposed for identification as an SVHC in 2022. The proposal was based on concerns that it met the criteria for being very persistent and very bioaccumulative (vPvB) under Article 57(e) of the REACH regulation. However, following the proposal, ECHA conducted a more in-depth scientific assessment. After carefully evaluating additional data and considering extensive feedback provided by various stakeholders, the agency concluded that the substance does not meet the vPvB criteria.
As a result of this comprehensive review, ECHA confirmed the withdrawal of the proposal in September 2025. With this removal, the SVHC Registry of Intention is currently empty.

ECHA Agrees to Identify DBDPE as a SVHC
On October 9, 2025, the European Chemicals Agency (ECHA) announced that its Member State Committee (MSC) has formally agreed to identify 1,1'-(1,2-ethanediyl)bis[pentabromobenzene], known as Decabromodiphenyl ethane (DBDPE, CAS No. 84852-53-9), as a Substance of Very High Concern (SVHC).
The proposal for identification was based on the substance's properties as very Persistent and very Bioaccumulative (vPvB), meeting the criteria under Article 57(e) of the REACH regulation.
DBDPE is a widely used flame retardant, often marketed as an environmentally friendly replacement for decaBDE. It is commonly found in various plastics, including HIPS, ABS resins, PVC, and PP.
ECHA is expected to formally add DBDPE to the SVHC Candidate List in November 2025. This decision marks a significant step in advancing the regulatory phase-out of hazardous brominated flame retardants within the EU.

EU Regulates Dechlorane Plus Under POPs Regulation Recast)
On September 25, 2025, the EU published Regulation (EU) 2025/1930 in its Official Journal, formally adding Dechlorane Plus (CAS No. 13560-89-9 and its isomers) to the list of restricted substances under the POPs Regulation. The law enters into force 20 days after publication, bringing the total number of substances on the EU POPs list to 32. According to the new regulation, from April 15, 2028, the concentration of Dechlorane Plus in substances, mixtures, or articles shall not exceed 1 mg/kg (0.0001%). A transitional limit of ≤1 000 mg/kg (0.1%) is permitted before this date.
Exemptions are provided for critical uses, such as aerospace, defense, and medical imaging, until February 26, 2030. Furthermore, continued use is permitted for specific equipment (like industrial machinery) and spare parts manufactured using Dechlorane Plus, allowing use until product end-of-life or 31 December 2043.

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