Japan Proposes Four New Mandatory SDS Notification Items Under ISHL

Why Is Japan Proposing the SDS Amendment?

Japan's workplace chemical-management framework relies on businesses conducting risk assessments and selecting exposure-control measures based on hazard information received through the supply chain. MHLW considers sufficiently specific information essential for identifying substances, choosing appropriate personal protective equipment and determining which regulatory controls apply to each component.

The proposed amendment follows recommendations issued by Japan's Labour Policy Council in January 2025. Those recommendations called for the legally required notification items to be expanded so that downstream workplaces can conduct more accurate risk assessments.

This proposal is separate from Japan's earlier ISHL changes concerning SDS delivery methods, review frequency, recommended uses and concentration disclosure. REACH24H previously summarized those changes in Japan Revises Rules for SDS and Labelling Under ISHL.

What Four SDS Information Items Would Be Added?

1. Component Identifiers Such as CAS Registry Numbers

The current legal notification items refer to chemical names, components and concentrations, but the proposed amendment would expressly add a widely used component-specific identifier. In practice, a CAS Registry Number or another appropriate unique identifier can help downstream users distinguish substances with similar or variable names and search the correct hazard and regulatory information.

2. More Specific Respiratory-Protection Information

The proposal would require suppliers to state the type of respiratory protective equipment appropriate for the component. Where a gas mask or similar device is used, the information would also need to identify the relevant cartridge or canister type. This is intended to replace overly general statements that do not give workplaces enough information to select appropriate equipment.

3. Materials Unsuitable for Impermeable Protective Gloves

The SDS information would need to identify materials that are unsuitable for impermeable protective gloves for the component concerned. Because glove performance varies by chemical and material, suppliers may need to verify whether their existing Section 8 information is sufficiently specific and supported by reliable compatibility data.

4. Regulatory Classification for Each Component

For mixtures, the proposal would require component-level information on the relevant chemical category or regulatory classification. The official summary refers to clearer communication of whether individual components are subject to applicable regulatory controls, including categories covered by special workplace chemical rules or hazardous-material provisions. This would help downstream users connect a specific ingredient with the control measures that may apply.

Would Japan's Container Label Requirements Also Change?

The proposed amendment addresses the information notified under Article 57-2(1) of the Industrial Safety and Health Act and Article 34-2-4 of the Ordinance. It does not propose corresponding changes to the separate label-display items under Article 57. Companies should therefore distinguish the proposed SDS and notification updates from Japan's existing container and package labeling requirements.

Proposed Timeline

The planned timetable gives companies an extended preparation period, but the final legal text and any implementing guidance may refine how the new information should be presented. Companies should therefore prepare their data and systems while monitoring the final requirements.

Who Should Start Preparing?

• Chemical manufacturers and formulators supplying substances or mixtures to customers in Japan.

• Overseas exporters that provide composition, hazard or protective-equipment information to Japanese importers and distributors.

• Japanese importers and suppliers responsible for delivering compliant SDS information downstream.

• Regulatory affairs, EHS, product stewardship and SDS-authoring teams maintaining Japan-specific documents and databases.

What Companies Can Do Now

1. Identify affected products. Map substances and mixtures supplied into Japanese workplaces and confirm which entity prepares or issues the Japan-market SDS.

2. Run an SDS data-gap review. Check whether component identifiers, respiratory-protection details, unsuitable glove materials and component-level regulatory classifications are already available.

3. Verify the supporting data. Review supplier information, hazard data and glove or respirator compatibility references before adding more specific statements.

4. Assess authoring systems and templates. Confirm that Japan-specific SDS databases and workflows can capture and maintain the proposed fields at component level.

5. Monitor the final text. Do not treat the proposal as an effective obligation before promulgation; track the October 2026 finalization and subsequent guidance.

How REACH24H Can Support Global SDS Compliance

REACH24H's Global GHS/SDS/MSDS/Label Compliance services support companies managing hazard communication across Japan and other major markets. Depending on the project scope, REACH24H can assist with:

• SDS authoring and translation for market-specific requirements;

• SDS review and updating against current jurisdictional rules;

• Label design and verification; and

• Coordination of multi-market GHS and SDS compliance requirements.

Companies preparing for the proposed Japan amendments can use the transition period to identify information gaps, align suppliers and update SDS workflows before the planned 2030 effective date.

Recommended Reading

• Japan CSCL and ISHL Compliance Services

• Japan Revises Rules for SDS and Labelling Under ISHL

• Japan Publishes SDS Guidance for New ISHL Requirements

Official References

• e-Gov Public Comment: Proposed Amendment to the Ordinance on Industrial Safety and Health (Case No. 495260154)