Japan Expands Scope of Substances Subject to Mandatory GHS Compliance (Update)

Update On Sep 23, 2025：

On September 19, 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) issued Ministerial Ordinance No. 90 of Reiwa 7(2025), amending the previously published Ministerial Ordinance No. 12 of Reiwa 7. 

This amendment advances the effective date of the Removal of two substances from Schedule 2 from April 1, 2027 to September 19, 2025. In other words, starting from that day (September 19, 2025), the two substances are no longer subject to mandatory SDS and labeling requirements under Japan’s Industrial Safety and Health Act.

On the same day, the MHLW also issued Public Notice No. 247 of Reiwa 7(2025), removing Triphenyl phosphate(CAS: 115-86-6) from the list of Substances with Concentration Standards, which was originally scheduled to take effect on October 1, 2025. As a result, the number of substances with concentration standards to be enforced on October 1, 2025, will decrease from 112 to 111. (read more)

Update On Aug 5, 2025：

On July 29, 2025, Japan's Ministry of Health, Labour and Welfare (MHLW) issued a proposal for public comment, planning to advance the effective date for the "Removal of the two substances from Schedule 2." The original effective date was April 1, 2027, but the MHLW plans to implement this change immediately.

Meanwhile, the effective date for the "Addition of 155 substances to Schedule 2" remains unchanged and is still April 1, 2027.

Following the public comment process initiated last year, on February 19, 2025, the Japanese Cabinet issued the “Cabinet Order Amending the Enforcement Order of the Industrial Safety and Health Act” (Cabinet Order No. 35 of Reiwa 7). This order expands the scope of substances subject to labeling and SDS requirements as detailed below.

On the same day, the Ministry of Health, Labour and Welfare (MHLW) announced amendments to the “Industrial Safety and Health Regulations (ISHR)” through Ministerial Ordinance No. 12 of Reiwa 7.

The amendment specifically targets Schedule 2 of the ISHR (substances subject to labeling and SDS provision obligations). The key changes are as follows:

1. Addition of 155 substances to Schedule 2: This is due to the expansion of the scope of substances subject to labeling and SDS;

2. Removal of the following two substances from Schedule 2: These substances were removed because they were not classified as hazardous or harmful under the government’s GHS classification as of March 31, 2024.

Effective Date

• Effective Date for Both the Cabinet Order and Ministerial Ordinance: April 1, 2027

Transitional Measures

• Article 57, Paragraph 1 of the Industrial Safety and Health Act (on labeling requirements) will not apply to substances existing as of the effective date until March 31, 2028.

The composition of substances subject to labeling and SDS obligations under the Industrial Safety and Health Act as of April 1, 2027, is as follows:

The list of target substances is available for download here.