Japan
Japan Consults On Updated Chemical Labelling And SDS Scope
Japan proposes updating the classification reference date for chemical labelling and safety data sheets. Most changes would apply in April 2029, with specified changes taking effect on promulgation.
Dr Steven Brennan
2 min readAI-drafted, expert reviewed
Japan’s Ministry of Health, Labour and Welfare has opened a consultation on amendments to chemical labelling and safety data sheet requirements under the Industrial Safety and Health Act framework. Published on 20 October 2026, the proposal remains a draft.
It would update the national classification reference date from 31 March 2025 to 31 March 2026. The associated tables contain additions, a deletion and changes to substance names or scope. The amendments concern substances covered by labelling and safety data sheet obligations.
Main Changes Proposed For April 2029
The Cabinet Order overview proposes commencement on 1 April 2029, with promulgation planned for February 2027.
The Ministerial Ordinance overview provides an earlier start for specified changes. The deletion in Overview Table 2 and amendments in Table 3 entries 2 and 3 would apply on promulgation. The other amendments would follow the April 2029 date.
Existing-Stock Labelling Transition
The Cabinet Order draft provides a one-year transition from the Article 57(1) labelling requirement for newly added substances already existing at commencement. The provision concerns labels; it does not create an equivalent safety data sheet exemption.
Comments are due by 18 November 2026 at 16:00 Japan Standard Time. The consultation documents do not establish an adopted commencement date.
Questions about this change
When would Japan’s October 2026 chemical labelling and SDS amendments apply?
The proposal sets 1 April 2029 for the main amendments. The deletion in Overview Table 2 and changes in Table 3 entries 2 and 3 would apply on promulgation. These dates remain proposed; the consultation does not itself change the law.
Would Japan’s proposed existing-stock transition exempt safety data sheets?
No. The draft describes a one-year transition for the Article 57(1) labelling requirement for newly added substances already existing when the changes commence. That provision is not an exemption from supplying safety data sheets.
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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