Japan Updates ISHA Labelling and SDS Obligations

Japan has released the latest update to the Industrial Safety and Health Act (ISHA) Substances Subject to Labelling and Safety Data Sheet (SDS) Delivery System, significantly expanding the scope of regulated chemicals.

The update, published on 18 December 2025, adds 779 chemical substances to the list of substances requiring mandatory labelling and SDS delivery. The revised requirements will take effect on 1 April 2026.

Overview of the Latest ISHA Revision

The revised ISHA list strengthens Japan’s workplace chemical safety framework by extending hazard communication obligations to a wider range of substances. The update ensures that workers and downstream users receive clear hazard information through standardized labels and SDSs.

This revision forms part of Japan’s ongoing efforts to align domestic chemical management practices with internationally recognized GHS-based hazard communication standards.

Effective Date and Compliance Timeline

The expanded ISHA requirements will become legally enforceable on 1 April 2026. From this date:

• Newly listed substances must carry compliant hazard labels
• Suppliers must provide Japanese-language Safety Data Sheets (SDSs)
• Employers must ensure proper hazard communication in workplaces handling these substances

Companies are encouraged to use the transition period to update internal systems and documentation.

Regulatory Basis Under the Industrial Safety and Health Act

Under Japan’s Industrial Safety and Health Act, chemical substances posing physical or health hazards must be communicated through:

• GHS-compliant labelling, and
• SDS delivery to downstream users and workers

The substance list is regularly reviewed and updated by the Ministry of Health, Labour and Welfare (MHLW) to reflect evolving hazard classifications and scientific knowledge.

Impact on Industry and Supply Chains

The addition of 779 substances significantly broadens the compliance scope for businesses operating in Japan.

Companies involved in the manufacture, import, distribution, or use of chemicals should:

• Review product portfolios against the updated ISHA list
• Update labels and SDSs for newly covered substances
• Align workplace safety procedures and employee training with the new requirements

Early preparation will help ensure uninterrupted compliance ahead of the April 2026 enforcement date.

Next Steps for Compliance

The latest ISHA update reinforces Japan’s commitment to improving workplace chemical safety through enhanced hazard communication. Businesses should closely monitor further guidance from MHLW and take proactive steps to meet the expanded labelling and SDS delivery obligations.