Japan to Expand Scope of Substances Requiring Labels and SDS under the ISHL

Editor's Note: This article was originally published in November 2025 to report on the consultation opportunity specifically for foreign stakeholders, updated on Feb 5, 2026, to cover the start of the domestic public comment period in Japan regarding the draft Cabinet Order and Ministerial Ordinance, and further updated on April 9, 2026, to reflect the official promulgation of the amendments.

Update (April 13, 2026):

On March 31, 2026, Japan officially promulgated the “Cabinet Order for Partial Amendment to the Order for Enforcement of the Industrial Safety and Health Act” and the “Ministerial Ordinance for Partial Amendment to the Ordinance on Industrial Safety and Health” in the Official Gazette, finalizing the proposals drafted in January.

Under these amendments, 36 substances have been added to Appended Table 2 of the "Ordinance on Industrial Safety and Health" as substances subject to mandatory labeling and SDS delivery. The enforcement date is April 1, 2028. However, a grace period applies: for existing stocks of these 36 target substances present on the date of enforcement, the mandatory labeling provisions will not apply until March 31, 2029.

The list of substances subject to mandatory labeling and SDS delivery under the Industrial Safety and Health Act (effective April 1, 2028) can be downloaded here.

On January 23, 2026, the Ministry of Health, Labour and Welfare (MHLW) published the “Draft Cabinet Order for Partial Amendment to the Order for Enforcement of the Industrial Safety and Health Act” and the “Draft Ministerial Ordinance for Partial Amendment to the Ordinance on Industrial Safety and Health”. The public comment period for these proposals is open until February 22, 2026.

Draft Cabinet Order for Partial Amendment to the Order for Enforcement of the Industrial Safety and Health Act

1. Extension of Classification Period: Regarding the criteria for selecting chemical substances subject to mandatory labeling and SDS delivery, the reference period for government-conducted chemical classification results will be extended from "until March 31, 2024" to "until March 31, 2025."

Draft Ministerial Ordinance for Partial Amendment to the Ordinance on Industrial Safety and Health

1. Addition of Substances: Following the amendment to the "Order for Enforcement" mentioned above, 36 substances will be added to Appended Table 2 of the "Ordinance on Industrial Safety and Health" as substances subject to mandatory labeling and SDS delivery. Details of the 36 substances under consideration can be found here.

2. Preservation of Records for Carcinogenic Substances: Regarding the preservation of records for carcinogenic substances, if a substance was designated as carcinogenic at the time the record was created, the record must be preserved for 30 years, even if the substance is subsequently removed from the designation.

Scheduled Promulgation and Enforcement Dates

• Promulgation: Late March 2026

• Enforcement: April 1, 2028

Note: The amendment regarding carcinogenic substances (record preservation) will take effect on the date of promulgation.

Previous article issued on November 27, 2025:

Japan’s Ministry of Health, Labour and Welfare (MHLW) has announced that it will conduct a public consultation on the “Review of Regulations Related to Substances Subject to Mandatory Labeling and SDS Provision under the Industrial Safety and Health Act.”

This review aims to expand the scope of substances requiring risk assessment—namely, those subject to mandatory hazard communication (labels and SDS)—in line with strengthened chemical management measures under the Industrial Safety and Health Act (ISHL).

1. Background and Purpose

Under Articles 57 and 57-2 of the Industrial Safety and Health Act, suppliers of chemical substances that may pose health hazards to workers are required to provide hazard information through labeling on containers and the provision of SDS.

The list of substances subject to these obligations is regularly updated based on the results of government-led GHS classifications.

2. Key Revision: Addition of New Target Substances

Currently, the scope of substances subject to labeling and SDS obligations is defined based on chemicals classified up to March 31, 2024. The current revision proposes to extend this cutoff date to March 31, 2025.

As a result, chemicals newly classified under GHS during FY2024 (April 1, 2024 ~ March 31, 2025) will be added to the regulatory scope. Specifically, a total of 36 substances are proposed for addition.

3. Public Hearing for Foreign Stakeholders

In accordance with the “Handling of the Establishment of Standards and Certification Systems of Japan,” MHLW will provide an opportunity for foreign stakeholders to present their opinions.

1. Scheduled Date and Time
   December 9, 2025 (Tuesday), 15:30–16:30 (GMT+9)

2. Location
   Room 16, 5th Floor, Central Government Building No. 5
   (1-2-2 Kasumigaseki, Chiyoda-ku, Tokyo)
   Online participation (Webex or Teams only) will also be accepted.

This allows overseas companies exporting chemicals to Japan, as well as other stakeholders, to submit comments. Those wishing to present opinions must follow the designated application procedures set by MHLW.

The amended obligations for labeling and SDS provision are scheduled to take effect in April 2028.