Interview | Expert's Insights into Japan GHS Updates

The updated JIS standards related to Japan GHS (JIS Z 7252: 2019＆JIS Z 7253: 2019) have been now formally enacted from 25th May 2022. These updated versions contain significant changes in Japan GHS classification as well as several changes in hazard communication. ChemLinked invited Dr. Toru Suzuki, who is a former General Manager of Chemicals Management dept. of Japan Chemical Industry Association (JCIA), to share his insights into the latest framework of Chemical Management around GHS in Japan including the updated version of JIS standards and some points to note for companies exporting chemicals to Japan. More details about Japan GHS updates are available in ChemLinked’s webinar held on June 30, 2022.

1. Which GHS building blocks are NOT adopted/included in Japan GHS?

Cat. 5 of Acute toxicity, Caty. 3 of Skin irritation, Cat. 2 of Aspiration hazard.

2. Is there an exemption for labelling of small items, e.g. 3 ml or 10 ml containers as we have in EU?

No.

3. What is the allowance for masking a chemical weight %/concentration on an SDS? Can we use a range of any size to mask an existing weight %/concentration, for ingredients that are not on the ISHA, PRTR, or PDSCL law?

It depends on the law. You need to check three relevant laws and regulations. For chemicals that do not fall under any of the three laws, you can use a range of any size to mask an existing weight %/concentration for ingredients.

4. Is Japan GHS working the same way as for European one (so-called CLP) regarding the Biocide Active Substances or Products: i.e. exempted for registration and evaluation, but applicable for classification and SDS?

5. In SDS section 15, what regulations shall be listed?

At least, ISHA, PRTR and PDSCL are required.

6. Is it obligatory to fill in at section 1 of a Japanese SDS the contact details of the OEM partner used that manufacture the chemical product but does not own the product?

What should be mentioned in SDS Section 1 is the name of the supplier, not the manufacturer.

7. Will there be a harmonized list (mandatory) of substances for classification and labelling under Japan GHS?

No.

8. When will the new GHS version be applicable?

The updated JIS standards (JIS Z 7252: 2019 & JIS Z 7253: 2019) have been formally come into force from May 25, 2022.

9. What is the basis of GHS hazard classification on the substances at NITE site? The GHS hazard classification of substance is extremely different from other parts of the world.

10. Is this GHS change and hazardous communication applicable to feed additive industry which is in business to business setting?

You must comply with the Feed Safety Law when communicating information about feed additives.

11. Does obligations to make effort means this requirement is optional for manufacturer or Importer to follow?

It is duty without penalty.

Webinar Recommendation

For more insights from Dr. Toru Suzuki on Japan GHS, welcome to watch ChemLinked webinar held on June 30, 2022, which covers main updates on JIS Z 7252: 2019 ＆ JIS Z 7253: 2019.

Both the video and the presentation slides are available.

About the Expert:

Dr. Toru Suzuki

Regulatory Compliance Senior Specialist from Japan Chemical Database Ltd.

Dr. Toru Suzuki is an experienced regulatory consultant and has successfully contributed to developing the GHS system on Chemical Industry in Japan as a former General Manager of Chemicals Management dept. of Japan Chemical Industry Association (JCIA). One of his achievements is also recognized as a member of the drafting committee of the JIS standard on GHS in the Industry.