Japan
Japan Proposes Updating Carcinogen Scope For Workplace Records
Japan is consulting on the carcinogen designation used for workplace records retained for 30 years. The proposal changes classification reference dates, with application planned for April 2029.
Dr Steven Brennan
1 min readAI-drafted, expert reviewed
Japan’s Ministry of Health, Labour and Welfare is consulting on an update to the carcinogenic-substance designation used for workplace records retained for 30 years. The consultation published on 20 October 2026 concerns the designation’s scope, rather than a new retention period.
The draft overview describes existing requirements for medical-examination results and specified worker records under Article 577-2 of the Industrial Safety and Health Regulations.
Classification Reference Dates Would Change
The proposal moves the national Category 1 carcinogen classification reference date from 31 March 2025 to 31 March 2026. It also changes the window for excluding substances subsequently reclassified outside Category 1: from 1 April 2025–31 March 2027 to 1 April 2026–31 March 2028.
The overview provides no net number of substances added. The designation concerns risk-assessment target substances and includes exclusions for ethanol and specified special-management substances. It is not a blanket designation of every carcinogen.
Application Proposed For April 2029
The overview proposes application on 1 April 2029, with publication of the notice planned for February 2027. The measure has not been adopted through this consultation.
Comments must arrive by 18 November 2026 at 16:00 Japan Standard Time.
Questions about this change
Does Japan’s October 2026 carcinogen proposal change the 30-year retention period?
No. The draft updates the scope of designated carcinogenic substances through classification reference dates. Its overview describes existing 30-year retention requirements for medical-examination results and specified worker records.
When would Japan’s proposed carcinogen designation update apply?
The draft overview proposes application on 1 April 2029, with the notice planned for February 2027. Comments close on 18 November 2026 at 16:00 Japan Standard Time. These remain consultation proposals.
Dr Steven Brennan
CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.
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