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Japan to Add 155 Substances Subject to Mandatory GHS Compliance

Japan to revise ISHL Enforcement Order to broaden the scope of substances subject to mandatory GHS compliance.

Japan’s Ministry of Health, Labour and Welfare has announced plans to host a public meeting on September 20, 2024, to gather stakeholder opinions on expanding the list of substances subject to mandatory labeling and Safety Data Sheet (SDS) requirements under the Industrial Safety and Health Law (ISHL).

This meeting is open to producers and importers of the relevant substances, regardless of nationality, although participants must present their comments in Japanese. Interested companies are encouraged to submit their requests to attend via email ([email protected]) or mail by September 17.

The proposed regulatory revisions relating to GHS include:

  • Amendments to Article 18 of the ISHL Enforcement Order

  • Changes to Schedule 2 of the Ordinance on Industrial Safety and Health, which will include the addition of 155 substances and the removal of 2 substances.

In August 2023, Japan’s MHLW amended the ISHL Enforcement Order (CL news). According to the revised provisions under Article 18-2 of the ISHL Enforcement Order, which will take effect on April 1, 2025, chemical substances subject to the mandatory SDS and labeling requirements are those that were officially classified as hazardous by March 31, 2021. The revision proposal to Article 18 aims to extend this deadline to March 31, 2024, allowing for the inclusion of additional substances that have been classified as hazardous since the original cutoff date.

Following the proposed rules, 155 additional substances will be added into the list of substances subject to mandatory labeling and SDS, as well as their content thresholds for mixtures. In addition, two substances will be deleted from the existing list. The substances details can be accessed here.

This public communication can be viewed as a preliminary effort by the authorities to collect industry feedback, rather than a formal call for comments. Based on previous experiences, it may take an additional 1-2 years for the proposed regulatory revisions to be fully implemented.

For more information, please visit the official notice here.

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