On March 27th, 2019, Japan’s Ministry of Health, Labor and Welfare (MHLW) published on the official gazette 198 chemical substances[1] as existing chemical substances under the Industrial Safety and Health Law (ISHL). They were assigned with ISHL numbers from 27474 to 27671.
New chemical substances need to be notified under ISHL and the Chemical Substances Control Law (CSCL) respectively. For CSCL, the notified substances are added to the Inventory of Existing and Notified Substances (ENCS)[2] five years after the notification is completed. For ISHL, the notified new substances will be published as existing substances after one year.
By default, existing substances under CSCL are also considered existing substances under ISHL, while ISHL also has its own inventory of notified substances. Thus companies need to keep track of the two inventories to see if their chemical substances are listed as existing substances.
The ISHL inventory [3] consists of 4 main parts:
Existing chemical substances stipulated by the government (including basic elements and natural chemicals)
New chemicals published by MHLW (similar to this batch)
Certain chemicals that are regarded as existing chemical substances
Polymers that are regarded as existing chemical substances


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