A Comprehensive Look at PFAS in Japan: From Contamination to Regulations

PFAS is a category of Persistent Organic Pollutants (POPs) that have received widespread attention in European and American countries for over a decade. This category includes thousands of compounds such as PFOA, PFOS, PFNA, PFHxS, and PFBA, which are difficult to decompose and can easily accumulate in the environment. Japan has relatively lenient PFAS regulations, but is still studying the risks they pose to human health. There will be expected to be more detailed regulatory requirements in the future.

This article starts with PFAS pollution in Japan and examines the current restrictions on these substances in Japan.

PFAS Contamination: Concerns Raised Over PFAS Detection

1. Standards for PFAS in Tap Water

On April 1, 2020, Japan Ministry of Health, Labor and Welfare (MHLW) designated "PFOS and PFOA" as items for water quality management goals and set a provisional target value of "50ng/L for the combined value of PFOS and PFOA." These values are based on the assumption that a person weighing 50kg consumes 2L of water without any negative health effects every day in their entire life .

2. Serious PFAS Contamination

According to the survey results for the 2022 fiscal year released by the Ministry of the Environment (MOE) in March 2024, PFAS concentrations above the national standard were detected at 111 out of 1,258 sampled locations in rivers and groundwater in 38 prefectures. The 111 non-compliant samples are distributed in 16 prefectures such as Osaka and Okinawa.

Additionally, Japan Broadcasting Corporation (NHK) reported that in October 2023, PFAS was found to exceed the national standard in some areas of Japan. For example, authorities detected that PFAS concentrations were 28 times higher than the Japanese government's provisional upper limit (50ng/L) in the tap water of Okayama Prefecture, and more than 60 times higher than the limit (0.63ng/L) set by the European Food Safety Authority (EFSA) in 2020.

This screenshot is a broadcast clips by NHK on June 23, 2024. It indicates that PFAS levels in tap water in Okayama Prefecture exceeded the standard by 28 times.

As concerns about PFAS detection continue to rise, the government has requested that local governments and water supply companies provide the results of previous water quality tests by the end of September 2024, in order to understand the current situation of PFAS detection in tap water across the country.

3. Risks to Human Health

PFAS's impact on human health includes reported increases in cholesterol levels and carcinogenic effects, but the scientific understanding of PFAS is still lacking on an international level.

In Japan, MOE has released the Question and Answer Collection on PFOS and PFOA, which states that Japan has no confirmed cases of individual health problems caused by the ingestion of PFOS and PFOA .In addition, MOE is making efforts to gather information on toxicity and monitor the detection of PFAS.

Current Supervision

PFAS is widely used in non-stick coatings, waterproof clothing materials, cosmetics, skincare products, and food packaging due to its waterproof, oil-resistant, and heat-resistant characteristics. But comparing to other countries, Japan is very loose on PFAS supervision.

1. Chemicals

Japan mianly regulates the most widely used PFASs through designating them as Class 1 Specified Chemical Substances under the Chemical Substances Control Law (CSCL). Once a PFAS substance is designated as Class I Specified Chemical Substances, its manufacture, import and use would be prohibited in principle. In addition, the import of designated products containing these designated PFASs substances would also be prohibited. Details are as fowllows:

 2. Foods

As food packaging paper needs to be oil and water-resistant, paper plates and paper packs possibly contain PFAS. However, PFAS can potentially migrate from packaging materials into food, especially foods with high fat, salt, or acidity content. This can lead to direct exposure through consumption.

The US Food and Drug Administration (FDA) has banned the sale of oil-resistant coating agents containing PFAS. Furthermore, the ban has been fully implemented in various states, surpassing the federal mandate. Besides, The European Union (EU) has implemented regulations to limit PFAS concentrations in food and has proposed regulations for a variety of products, including food packaging.

Currently, there are no specific regulations or policies in Japan like those in Western countries. However, it is unlikely that regulations will be relaxed in the future. Taco Bell in the United States has announced that they would remove PFAS from all of its “consumer-facing packaging materials” by 2025. This has sparked a trend in the food and beverage industry to replace PFAS-containing packaging with alternatives. Products containing PFAS are not limited to packaging materials, but addressing the issue of food packaging materials should be the top priority, as they have a high potential to enter the body of consumers directly .

3. Cosmetics

PFAS is used for various purposes in cosmetics, such as water resistance, penetration, easy application, and smoothness. In particular, PFAS has been found in the following cosmetics in Japan, with higher levels detected in foundations and makeup primers:

• Sunscreen

• Liquid foundation

• Powder foundation

• Makeup primer

• Lipstick

• Nail polish

Japan has yet to enact specific regulations for PFAS in cosmetics. However, other countries have started to regulate PFAS. For example:

• On October 10, 2023, California passed the Assembly Bill No. 496 to ban the use of certain PFAS in cosmetics, which will go into effect in 2025.

• On January 30, 2024, New Zealand released a ban on the use of PFAS in cosmetic products by changing the Cosmetic Products Group Standard.