New Labelling and SDS Requirements Announced
On 16 May 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) issued a significant update to the list of substances subject to mandatory labelling and Safety Data Sheet (SDS) delivery under the Industrial Safety and Health Act (ISHA). This marks a major step in strengthening chemical safety and workplace hazard communication.
Major Expansion in Chemical Coverage
The updated regulation now encompasses 2,316 chemical substances, significantly expanding from the initial seven chemicals designated in March 2025. These chemicals are now subject to strict GHS-compliant labelling and SDS requirements to enhance transparency and protect worker health.
Phased Implementation Timeline
To support industry preparedness, MHLW introduced a two-phase enforcement schedule:
• Effective 1 April 2025: 1,530 substances covered
• Effective 1 April 2026: Additional 779 substances covered
This phased approach gives companies time to align compliance measures across their product lines and supply chains.
Compliance Obligations for Industry
Companies involved in manufacturing, importing, distributing, or handling listed chemicals must ensure:
• Proper labelling following GHS standards
• Accurate and complete SDSs, written in Japanese
• Up-to-date risk assessments and employee safety protocols
• Robust documentation and recordkeeping for regulatory audits
These measures apply not only to pure substances but also to mixtures containing regulated chemicals above designated thresholds.
Implications for Chemical Stakeholders
This regulatory shift presents critical compliance implications:
• Increased oversight for unlabelled or undocumented substances
• Operational challenges in updating SDSs and hazard labels
• Strategic importance in training staff and aligning internal systems with ISHA requirements
Proactive adaptation will be essential for avoiding disruption and maintaining access to the Japanese market.
Preparing for Compliance
To comply with the upcoming enforcement dates, companies should:
• Review product portfolios against the updated ISHA list
• Update SDSs and ensure local language accuracy
• Replace outdated labels with GHS-aligned formats
• Communicate changes across supply chain partners
Early action will reduce risk and enhance workplace safety in accordance with Japanese regulations.
Japan’s expanded ISHA substance list highlights the government’s commitment to occupational health and chemical transparency. Businesses must act promptly to meet the evolving requirements, with full compliance expected by April 2026. Aligning now with the updated framework will ensure smoother regulatory navigation and safer operations.
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