On August 24, 2026, Japan's Ministry of Health, Labour and Welfare (MHLW) opened a public comment period on a draft ministerial ordinance partially amending the Ordinance on Industrial Safety and Health Regulations, with comments due by September 23, 2026. The amendment centers on the notification items for safety data sheets (SDS) and labels, adding four new items to be provided, and directly affects the SDS preparation and provision obligations for chemicals placed on the Japanese market.
Amendment Contents
Article 34-2-4 of the current Ordinance on Industrial Safety and Health stipulates the notification items for SDS and labels; the draft amendment proposes to add the following four items to that Article:
- Identification numbers for ingredients: numbers that can identify an ingredient and are widely used as numbers intrinsic to that ingredient, such as the CAS Registry Number (excluding substances to which no such number has been assigned);
- Suitable respiratory protective equipment: types of respiratory protective equipment suitable for the ingredient, including the types of canisters where gas masks or the like are used;
- Unsuitable glove materials: substances unsuitable as materials for impermeable protective gloves appropriate for the ingredient;
- Chemical classification of ingredients: indication, for each ingredient contained, of the regulatory classifications under the applicable laws and ordinances, etc., covering substances subject to the special rules, substances subject to risk assessment, chemical substances liable to cause skin disorders or the like, carcinogenic substances, and substances for which concentration reference values have been established, among others.
Amendment Background
The draft is based on the FY2024 interim summary (the part on notification of hazard information) compiled on August 30, 2024, by the Expert Meeting on Chemical Substances Management under the Safety and Health Department of MHLW's Labour Standards Bureau. The interim summary noted that the compliance rate for the obligation to provide SDS and similar documents is around 90%, with nearly 10% of workplaces still failing to fulfil the obligation, and that the notification items need to be enhanced; meanwhile, penalties for false notification have been strengthened by the Act on Partial Amendments to the Industrial Safety and Health Act and the Working Environment Measurement Act promulgated on May 14, 2025. The Japan Paint Manufacturers Association (JPMA) calls on relevant companies to study the draft amendment carefully and actively submit comments.
ChemRadar Insights
In light of the above developments, CIRS reminds companies dealing with the Japanese market to note the following three points:
- SDS preparation requirements will rise: once the amendment enters into force, SDS and labels must carry the four new notification items; companies should check their existing SDS against the new items in advance and allow time for revisions and internal process adjustments;
- Make use of the comment window: companies with comments or questions on the draft may submit them by September 23, 2026 via the e-Gov public comment portal (https://public-comment.e-gov.go.jp/pcm/detail?CLASSNAME=PCMMSTDETAIL&id=495260154&Mode=0);
- Ensure SDS are truthful and accurate: with penalties for false notification now strengthened, companies should ensure that all entries are truthful, accurate, and well-founded when preparing and updating SDS.
CIRS Services
CIRS can provide the following services for companies involved in chemical compliance in Japan:
- Japan new chemical substance search service
- Japan new chemical substance notification service
- Overall registration scheme development (data assessment/gap analysis/exemption analysis)
- Laboratory testing oversight service
- Communication and consultation with competent authorities and experts
- Regulatory training service
- Safety Data Sheet (SDS) and label preparation
