Japan Proposes Changes to Chemical Labelling and SDS Requirements

In Japan, suppliers of certain hazardous chemicals must provide labels and  Safety Data Sheets (SDSs) when supplying those chemicals to other businesses. These requirements fall under the Industrial Safety and Health Act (ISHA) and help employers identify chemical hazards, assess workplace risks and protect employees.

Which substances are covered matters for both chemical suppliers and their customers. A change to the regulated list can mean that a product needs a label or SDS for the first time, or that existing documentation needs to be checked against a revised substance entry.

Japan’s Ministry of Health, Labour and Welfare (MHLW) is now proposing amendments to the Enforcement Order of the Act and related ordinances. The proposal has been notified to the World Trade Organization under reference G/TBT/N/JPN/918, with comments open until 13 December 2026.

What would change?

The draft would revise the substances covered by mandatory labelling and SDS requirements. It includes additions to the list, exclusions for certain substances and changes to some substance names and entries.

The scope also covers preparations containing the affected substances. Suppliers therefore need to consider not only substances sold on their own, but also the composition of mixtures supplied to the Japanese market and any applicable concentration thresholds.

This is a change to workplace chemical information requirements, not a general ban on the substances concerned. Its purpose is to ensure that information about hazardous chemicals reaches the businesses and employees handling them.

When would the changes apply?

Adoption is proposed for January 2027, but the implementation dates differ between the substance groups:

• April 2029 for the substances in Appendix 1 and entries 1 and 4 in Appendix 3.
• January 2027 for the substance in Appendix 2 and entries 2 and 3 in Appendix 3.

These dates are provisional and may change before adoption. Companies should check the relevant appendix rather than assume that the April 2029 date applies to every amendment.

What happens next?

The WTO notification gives trading partners and stakeholders an opportunity to comment on the proposed requirements before adoption. Comments can be submitted through Japan’s Enquiry Point by 13 December 2026.

Once adopted, the amendments will be published in KAMPO, Japan’s Official Government Gazette. The notification itself does not bring the proposed requirements into force.

For companies supplying chemicals or mixtures to Japan, the first step is to compare the draft appendices with their product composition records. This will help identify which products may need new or revised labels and SDSs, and which proposed implementation date applies.

Source: WTO notification G/TBT/N/JPN/918 – Amendment to the Enforcement Order of the Industrial Safety and Health Act and related ordinances .