Taiwan’s restrictions on PFOA, PFOS, and nonylphenols substances take effect soon

Taiwan’s restrictions for the 397 PFAS substances, which it consulted with the public in October 2024, and Nonylphenols will take effect starting on 1 June 2025.  Industries have a short transition period to comply with the new restrictions.

Taiwan Ministry of Environment (MOE) announced on 13 May 2025 that it is adding 357 PFAS substances and 40 nonylphenol substances to the Listed of Toxic Chemical Substances and Their Operational Management.  These chemicals include: 

• 5 perfluorooctane sulfonic acid (PFOS), 

• 352 perfluorooctanoic acid (PFOA) and its salts and related compounds, 

• 12 nonylphenol substances

• 28 nonylphenol polyethoxylate substances

PFOA and PFOS restrictions

PFOA and PFOS are part of a group of chemical substances known as per- and polyfluoroalkyl substances (PFAS). PFAS poses health and environmental concerns because they are persistent organic pollutants, which requires a long time to break down. PFOA and PFOS have been prohibited and restricted, respectively, under the Stockholm Convention. Unlike the EU and some US states, which regulate the entire class of PFAS, Taiwan opts for regulating individual chemicals under the class.

Different regulatory deadlines for companies using and handling PFOA and PFOS. Those continuing to handle PFAS would be required to comply with new requirements.     

Nonylphenols

Nonylphenol and Nonylphenol polyethylene glycol ether are considered endocrine disruptors (ED).  These chemicals have been banned in detergent products. Starting on 1 December 2026, these substances would be prohibited, unless manufacturers could ensure that these substances are collected, treated and disposed of without contaminating the wastewater. They are restricted/ prohibited for use in:

• The manufacture of household, industrial and institutional cleaners.

• The manufacture of treatment of textiles or leather products.

• Metalworking

• Manufacture of pulp or paper 

However, the following uses are permitted: 

• Research, testing, education.

• Pharmaceuticals.

• Raw materials for synthetic resins and phenolic resins.

• Antioxidants.

• Stabilizers.

• Spermicides.

• Emulsifiers and dispersants for oils, dyes, pigments, and printing inks.

• Paints, coatings, adhesives.

Those who manufacture, import or distribute nonylphenol (CA 25154-52-3, 84852-15-3) and nonylphenol polyethoxylated alcohol (CAS 9016-45-9, 26027-38-3) or chemical mixtures containing these substances at a concentration greater than 5% must comply immediately with the various regulatory controls immediately. The deadlines for chemical mixtures containing these substances at a concentration between 1 and 5 percent, have been staggered.  

Implications for businesses 

The new amendment ushers in new restrictions and requirements for manufacturers and importers of nonylphenols, PFOA, and PFOS. Domestic manufacturers and importers will face additional regulatory burden. This change is expected to shift companies towards using little to no trace of these chemicals. However, it is unclear whether these rules would directly impact articles - hard, incorporated objects where the chemicals are not expected to be released into the environment - or imports of these products.  

While Taiwan opted to regulate substance by substance, the newly added PFOA and PFOS substances as well as the previous ban of 147 PFHxS substances and their salts indicate the country’s aim to eliminate the manufacture, import and use of these chemicals as well as the broader class of PFAS. Companies operating and selling products in Taiwan should consult the relevant rules and begin to shift their business strategies, which may include new product formulation or design and new supply chain engagement.

Regulatory & compliance activities	PFOS	Nonylphenols at concentration > 5%	Nonylphenols at concentration from 1% to 5%
Example	1 June 2025	Immediately	1 June 2025
Obtainment of liability insurance for the use and handling of the chemicals	1 December 2025 (6 months after the announcement)	Immediately	1 December 2025
Submission of the hazard prevention and response plan; Labelling of containers, packaging, operation sites and facilities, and preparation of safety data sheets; Preparation of emergency response which identifies detection equipments	1 June 2026	Immediately	1 June 2026
Completion of training for employees	1 December 2026	Immediately	1 December 2026
Completion of installation of safety measures and detection equipment	1 December 2026	Immediately	1 December 2026
Obtain necessary permits and approvals of the use of PFOS	1 December 2026	1 December 2026	1 June 2027