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The Japanese Ministry of Health, Labour and Welfare (MHLW) is currently planning a revision to the Industrial Safety and Health Law (ISHL). The overall direction of the revision has been discussed multiple times within the government since the end of last year, but no official document has been released for public consultation in Japan yet.
This revision involves multiple aspects of strengthening worker protection under the law. On March 3, 2025, MHLW notified the World Trade Organization (WTO) of the outline of the content related to "communication of chemical hazard information" in the amendment. It mainly includes the following three parts:
Introducing penalty provisions for non-compliance with hazard information notification obligations (SDS/labels);
Changing the requirement for companies to notify downstream users of changes to SDS/labels from the current "effort-based obligation" to a mandatory obligation;
Allowing the use of alternative names for certain substances in SDS/labels to protect confidential business information (CBI). (Substances eligible for alternative names will be officially designated.) Companies using alternative names must establish and maintain records in accordance with relevant requirements.
Background:
Japan is gradually expanding the range of substances requiring mandatory Safety Data Sheets (SDS) and labels under the Industrial Safety and Health Law (ISHL). The government's long-term goal is to include all substances that meet the Globally Harmonized System (GHS) hazard classification criteria within this mandatory scope. However, if companies fail to create and distribute SDSs and labels as required by law, worker safety protection cannot be effectively guaranteed.
Additionally, as the scope of mandatory SDS and label substances expands, some substances with lower hazards will also be included in the information communication category in the future. However, among these substances, some ingredient names may involve confidential business information (CBI). To address this, the Japanese government not only plans to introduce penalties for non-compliance with SDS and label requirements but also clarifies the rules for protecting CBI to alleviate companies' concerns about the risks of disclosing sensitive information.
This series of measures aims to ensure that workers can access adequate chemical safety information in the workplace while balancing companies' needs to protect trade secrets.
Implementation Plan:
The amendment is planned to take effect from April 1, 2026.
However, the implementation dates for points 1 and 2 mentioned above will be specified in a subordinate regulation within 5 years after the amendment is published.
