Japan Adds 36 Substances to Mandatory Labeling and SDS List Under ISHL, Effective 2028

On March 31, 2026, Japan promulgated amendments to the Japanese ISHL Enforcement Order that will bring 36 more chemical substances under mandatory container labeling and safety data sheet (SDS) delivery. The rules bite on April 1, 2028, with a one-year grace period for existing stocks, so chemical suppliers and importers have a clear window to reclassify products and prepare compliant labels and SDS.

The move flows from Articles 57 and 57-2 of the ISHL, which require suppliers of chemicals that may harm workers to push hazard information down the supply chain through labels and SDS. The roster of substances bound by these duties is refreshed periodically against the government's GHS classification work. This amendment widens the qualifying window for classification results from "up to 31 March 2024" to "up to 31 March 2025", sweeping in 36 substances newly classified during fiscal 2024.

The 36 substances were inserted into Appended Table 2 of the Ordinance on ISHL, broadening the hazard-communication scope. The full official set of substances subject to labeling and SDS delivery under the ISHL can be verified through MHLW's anzeninfo chemical safety database, and suppliers handling any of the newcomers must have labels and SDS ready before the 2028 deadline.

Mindful of practical lead times, MHLW built in a transition rule: for the 36 substances, the labeling duty is pushed back to 31 March 2029 for stock already held on the April 1, 2028 enforcement date, letting companies draw down existing inventory before full compliance sets in.

A separate clause, effective on promulgation, tightens record-keeping for carcinogenic substances. Where a chemical was designated carcinogenic when an exposure record was created, that record must now be retained for 30 years even if the substance is later dropped from the carcinogen list, closing a gap that had previously shortened retention once a designation lapsed.

For chemical manufacturers, importers and downstream users selling into Japan, the practical checklist is to screen product portfolios against the updated Appended Table 2, plan relabeling and SDS authoring for the 36 newcomers ahead of April 2028, and align carcinogen-record retention with the new 30-year rule from the March 2026 promulgation date.

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