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Japan to Subject 1,469 Substances for Mandatory SDS and Labeling Requirements under ISHL

Two batches of 1,469 hazardous substances are proposed to mandate SDS and labelling requirements under Japan ISHL.

The Japanese Ministry of Health, Labor and Welfare (MHLW) will listen to overseas stakeholders' opinions from March 14, 2023 on the second and third batches of candidate substances subject to mandatory SDS and labeling requirements under the Industrial Safety and Health Act (ISHL).

The two batches of candidate substances include:

  • Second batch: 651 substances identified in category 1 of hazard classes other than carcinogenicity, germ cell mutagenicity, reproductive toxicity (CMR) and acute toxicity, to be implemented from April 1st, 2025, and 

  • Third batch: 818 substances with health hazards in category 2 and below, or chemicals without health hazards but with physical-chemical hazards, to be implemented from April 1st, 2026. 

As previously reported by Chemlinked, the MHLW plans to subject about 1,800 hazardous chemicals to mandatory SDS and labelling requirements in three years (CL news). They will be designated in three batches from the officially classified 2,900 substances with GHS classifications. The first batch of 234 substances was officially released on February 24, 2022, and will be implemented on April 1, 2024 with a one-year buffer period granted until March 31, 2025 (CL news). They are of Category 1 carcinogenicity, germ cell mutagenicity, and reproductive and acute toxicity (possessing any one category and more). The second and third batches of candidate substances were initially proposed on the JNIOSH website on December 28, 2021, with the substance numbers being 675 and 827 respectively. This release is an update to the candidate substances proposed in 2021. 

These substances are expected to be added to Schedule 9 of ISHL Enforcement Order, with corresponding content thresholds for providing SDS and labels in Schedule 2 of the Ordinance on Industrial Safety and Health.

It should be noted that this time only comments from overseas stakeholders will be accepted. There will be subsequent steps, including WTO notification, and solicitation of opinions within Japan, before the amendments to the relevant regulations are officially released.

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