Taiwan Revises PFAS Proposal: 182 Substances Proposed as Concerned Chemicals, 14 as Toxic Chemicals

How the Proposal Changed

The Ministry of Environment's August 5, 2025 draft proposed listing 269 PFAS as concerned chemical substances. After receiving comments from domestic and international stakeholders and conducting further technical review, the authority reorganized the original group rather than simply deleting substances from the list.

The authority also moved one substance from the non-polymer annex to the polymer annex and raised the proposed control concentration from 0.1% to 1% by weight. PFAS gases, which formed a third category under the 2025 draft, have been deferred for further assessment due to their overlap with greenhouse gas controls and potential implications for refrigerant substitution.

How the 182 Substances Would Be Managed

The revised proposal separates the 182 concerned chemical substances into two annexes. The proposed duties depend on the substance category, the concentration of each listed substance and the operator's activity. The authority stated that the concentration threshold would be assessed for each listed PFAS individually, rather than against the combined concentration of all PFAS.

Uses for experiments, research, education and testing are identified as exclusions in the draft annexes. The draft also provides that substances or items already regulated under specified sectoral laws would not be controlled again under this measure. Applicability must still be assessed against the exact material, use and legal basis.

The authority described the proposal as a source-management and hazard-information disclosure measure, not a general PFAS use ban. Its meeting materials also explain that the framework targets chemical substances and raw materials; a finished product should not automatically be treated as regulated solely because it contains PFAS.

Proposed Transition Schedule

For operators already handling substances that would enter the 182-substance list, the current draft proposes the following transition schedule.

• From January 1, 2027: Begin monthly operational records and submit them quarterly as required. Other matters not assigned a separate transition date would apply from the effective date.

• By January 1, 2029: Obtain the applicable approval document and complete container, packaging, operating-site and facility labels, together with the required Safety Data Sheet.

These dates come from the draft for the 182 concerned chemical substances. They should not be assumed to establish the effective date or transition rules for the separate proposal covering 14 toxic chemical substances.

Which Companies Should Assess the Impact

The proposal is particularly relevant to chemical manufacturers and importers and to supply chains in electronics, semiconductors, specialty chemicals, materials and fluorochemical applications. A useful assessment should go beyond asking whether a product contains PFAS. Companies should determine:

• the CAS number of each PFAS and whether it appears in the final concerned-chemical list, the separate toxic-chemical proposal or the group still under review;

• whether the material is supplied as a substance, mixture, polymer, raw material or finished article;

• the concentration of each listed PFAS rather than only the total PFAS concentration;

• whether the Taiwan operation involves manufacture, import, sale, use or storage, and which local entity performs each activity;

• whether another listed law already controls the substance or item and whether the proposed exclusion applies; and

• whether supplier composition data, Chinese labels, Safety Data Sheets and operational records are available for the transition period.

Recommended Preparation Steps

1. Build a CAS-level inventory. Map PFAS in raw materials, mixtures and polymers against the revised annexes. Do not rely only on general supplier declarations such as "PFAS present" or "PFAS free".

2. Separate the regulatory pathways. Distinguish the 182 proposed concerned chemical substances from the 14 substances proposed for toxic chemical control and the 73 substances still under assessment.

3. Confirm concentration and activity. Check the concentration of each listed PFAS and identify the responsible manufacturer, importer, seller, user or storage operator in Taiwan.

4. Review exclusions carefully. Document whether an item is a chemical raw material, a finished article or a product regulated under another law. Avoid treating every PFAS-containing product as subject to the same duties.

5. Prepare documentation gaps. Identify missing composition data, Chinese labeling text, Safety Data Sheet content, reporting processes and approval-document needs, while keeping implementation plans flexible until the final announcement is published.

How REACH24H Can Help

REACH24H can support companies preparing for the proposed Taiwan PFAS controls with:

• CAS-level substance screening against the revised annexes;

• scope and exemption assessment based on the material, use and applicable legal basis;

• supply-chain role mapping for manufacturers, importers, sellers, users and storage operators;

• documentation review covering composition data, labeling, Safety Data Sheets, records and reporting; and

• planning for related TCCSCA obligations as the proposal moves toward formal announcement.

For a broader review of substance status, registration routes and adjacent chemical controls, see our Taiwan TCCSCA and OSHA chemical registration services.

We will continue to monitor the formal announcement, including any changes to the proposed scope, control thresholds, implementation requirements and transition arrangements, as well as any separate regulatory action concerning the 14 PFAS proposed for toxic chemical substance control.

Recommended Reading

• Taiwan Chemical Registration: 2027 Hazard and Exposure Assessment Deadline

• Chemical Management System and Latest Developments in Taiwan

Official References

• Chemicals Administration consultation meeting page

• Chemicals Administration consultation presentation

• Ministry of Environment 2025 draft announcement