JP Industrial Safety and Health Act — Phased Expansion of Substances Subject to SDS and Label Requirements (2025 and 2026)
ENFORCEMENT TIMELINE
April 1, 2025 (second phase addition) and April 1, 2026 (third phase addition, expanding to approximately 2,900 substances)
Overview
Following amendments to the Order for Enforcement of the Industrial Safety and Health Act and related ministerial ordinances, aimed at preventing occupational illness caused by chemical substances, the number of substances subject to mandatory provision of a safety data sheet (SDS), container and packaging labeling, and risk assessment is being expanded in stages, from approximately 900 substances to approximately 2,900 substances. Following the first phase in April 2024, which added 234 substances, a second phase takes effect on April 1, 2025, and a third phase on April 1, 2026, bringing a broad range of industrial chemicals, intermediates, and mixtures distributed and used in Japan within the scope of regulation.
Enforcement Timeline
May 2022: The amended government and ministerial ordinances are promulgated, fixing the schedule for expanding the covered substances.
April 1, 2024: The first phase takes effect, making SDS provision, labeling, and risk assessment mandatory for the newly designated substances.
April 1, 2025: The second phase takes effect, adding further substances and requiring the appointment of a protective equipment management officer, among other measures.
April 1, 2026: The third phase takes effect, completing the expansion to approximately 2,900 substances and the full transition to autonomous chemical management.
Business Impact
Chemical manufacturers, paint, adhesive, and ink manufacturers, and every manufacturing and processing business that handles these products need to comprehensively re-identify the covered substances contained in the products they manufacture, import, transfer, or use, and complete the update of their SDS and labels in line with the latest JIS Z 7253. Businesses that fail to keep pace with the expanding scope of covered substances face not only corrective recommendations and penalties for non-compliance but also the risk that downstream companies will halt supply from them.