Do you need help to comply with the new Japanese SDS requirements? ¡New practical guideline published!

Do you need help to comply with the new Japanese SDS requirements? ¡New practical guideline published!

The Japan Chemical Industry Association (JCIA) has published a guidance to help companies to meet new SDS and labeling requirements under the revised ISHL.

Although it's not an official document, it is considered “a high reference” because it was prepared in close collaboration with the Ministry of Health, Labour and Welfare ( MHLW ).

Last May 31, 2022, the MHLW amended the Ordinance of Industrial Safety and Health to introduce new requirements for the SDS and the labeling of hazardous chemicals.

The amendment added 234 new substances subjected to mandatory SDS and labeling requirements under the Industrial Safety and Health Act (ISHL). An obligation that will come into force on April 1, 2024, although industry companies have been granted a one year grace period, until March 31, 2025. And, apart from the addition of these 234 substances, the new regulation has introduced some other changes in the SDS requirements and delivery methods. Let's review some of the most relevant.

Information on recommended use

Suppliers must identify the intended product use, although it´s not necessary to include a complete list of potential uses. If the recipient of the chemical intends to use the product for purposes other than the ones listed on the SDS, they shall conduct a risk assessment. Besides, when there is a specific use that the supplier advises against, the use must be included.

SDS Delivery methods

The amendment includes two new SDS delivery methods:

  • a) Sending the link where the SDS is posted
  • b) Sending the QR code.

Besides, it is no longer required prior consent form the recipient.

More specific composition information

It is required the actual percentage by weight to be included on the SDS for the regulated substances in a mixture product. Along with the chemical name, the concentration information must appear, and it must include the exact percentage by weight.

Updates

From April 2024, it is mandatory to review the health hazards every 5 years. If there are any updates, the SDS must be updated and delivered to the downstream links within 1 year.

Labeling

From April 1, 2023, labeling is mandatory on containers in the factory if the subject chemical is transferred from one container to another or stored in a container after manufacture.

The public guidance published by the JCIA provides precise information regarding:

  • Recommended uses and restrictions.
  • Protective equipment to be used for the recommended uses
  • Display and non-disclosure of ingredients.

Our Chemeter software has the "Japan" module available, necessary to be able to carry out FDS that include the national regulation of the country according to the latest current updates. If your company sells its products in Japan, do not hesitate to contact us to learn more about this practical tool.

You can find more information here:

Guidance:

Japanese GHS / SDS and labeling regulation (english):