On July 29, 2026, Japan's Ministry of Health, Labour and Welfare (MHLW) promulgated MHLW Ordinance No. 116 of 2026 and MHLW Notice No. 279 of 2026, the supporting legislation to implement the individual exposure measurement provisions of the amended Industrial Safety and Health Act and Working Environment Measurement Act, which take effect on October 1, 2026. According to a notice forwarded by the Japan Paint Manufacturers Association on August 3, 2026, chemical, coatings, and other enterprises in Japan that carry out working environment measurement should pay attention to these supporting rules.
Background of the Supporting Legislation
This ordinance and notice implement the 2025 Act on Partial Amendments to the Industrial Safety and Health Act and the Work Environment Measurement Act. The amendment introduces a new system of "individual exposure measurement," with full implementation expected in fiscal year 2028. The ordinance and notice published now provide the preliminary rules for this system and take effect in step with the relevant provisions of the amendment.
Key Revision Points
The core content of this supporting legislation covers the following two areas:
- Clarifying the definition of working environment measurement: In line with the amendment to the Industrial Safety and Health Act, the relevant article (Article 65-3) has been redefined as "working environment measurement conducted to prevent health impairment." Based on this, the ordinance refines the circumstances that trigger the measurement obligation and its specific operational requirements.
- Establishing designation rules for designated bodies: The ordinance newly requires that working environment measurement of the individual exposure measurement type be carried out by "persons designated by the Minister of Health, Labour and Welfare"; Notice No. 279 further specifies the designation criteria for such designated persons.
Impact on Enterprises
Individual exposure measurement is a system that assesses the level of a worker's exposure to harmful substances. It will become one of the occupational health compliance obligations for employers in Japan, particularly in industries such as chemicals, coatings, and electronics that involve organic solvents, dust, or specified chemical substances. The publication of this ordinance and notice indicates that the supporting rules are taking shape, and enterprises should monitor the implementation timeline and plan ahead.
ChemRadar Insights
Enterprises engaged in chemicals, coatings, or related business in or with Japan should note the following:
- Track implementation progress: Follow the partial implementation schedule and subsequent milestones of the above amendment, especially the progress toward full implementation of the individual exposure measurement system.
- Assess applicability: Based on your operations, assess whether you will fall within the scope of individual exposure measurement and working environment measurement in the future.
- Check measurement body qualifications: This notice clarifies the designation criteria for "persons designated by the Minister of Health, Labour and Welfare." When you later commission individual exposure measurement services, confirm whether the body holds the corresponding designation.
