The Ministry of Health, Labour and Welfare opened four linked public consultations on 20 October that would widen the set of chemicals requiring hazard labels and safety data sheets (SDS), and remove one substance, diethyl phthalate, from the system. Comments close on 18 November. All four measures are drafts, not adopted rules.
What would be added
The core change sits in a proposed amendment to the cabinet order implementing the Industrial Safety and Health Act. It moves the classification cutoff from substances classed as hazardous by 31 March 2025 to those classed by 31 March 2026, so that the results of national classification work through the 2025 fiscal year feed the list. The classification follows Japanese Industrial Standard Z7252, which implements the UN's Globally Harmonized System.
A companion draft amending the Industrial Safety and Health Regulations turns that into names. An annex to its outline lists 35 substances to add, including triethylene glycol and natural rubber. A single entry is removed: diethyl phthalate. The annex says CAS numbers are shown for reference only, and that whether a substance is covered is decided by its name. It also lists name changes. Per its footnotes, lithium hydroxide monohydrate and the zinc salt of 2-mercaptobenzothiazole are added to existing entries, and non-fibrous silicon carbide is removed.
Dates differ by instrument
The cabinet order is planned for promulgation in February 2027 and enforcement on 1 April 2029. For substances newly added to the list that already exist on that date, the labeling duty would not apply for one year after the addition. The summary states this exemption for labeling only. The ordinance follows the same dates, except for the diethyl phthalate deletion and two name-change items (silicon carbide and barium metaborate), which would take effect on promulgation.
| Instrument | Proposed change | Planned issue | Planned application |
|---|---|---|---|
| Cabinet order | Classification cutoff moves from 31 March 2025 to 31 March 2026 | February 2027 | 1 April 2029 |
| Ministerial ordinance | 35 additions, diethyl phthalate removed, name changes | February 2027 | 1 April 2029; deletion and two name-change items on promulgation |
| Content-threshold notice | Annex 1 and 2 entries revised | February 2027 | 1 April 2029 |
| Exposure-limit notice | Diethyl phthalate and its limit removed | February 2027 | Date of notice |
| Technical guidance | Diethyl phthalate, sampling and analysis methods, and limit removed | February 2027 | Date of notice |
Content thresholds and exposure limits
A third draft revises the ministerial notice setting content thresholds, the percentage below which a mixture containing a listed substance falls outside the labeling and SDS duties. The amendment would rework entries in the notice's Annexes 1 and 2. The comparison tables show changes for antimony, lead, arsenic and fluorine compounds, and for entries such as dicyclohexylamine, silicon carbide and pentachlorophenol, with thresholds of 0.1, 0.3 and 1 per cent appearing in them. The notice is planned for February 2027 and would apply from 1 April 2029.
The other two drafts follow the diethyl phthalate deletion. One removes the substance and its exposure limit from the ministry's exposure-limit notice, which sets limits for 304 substances. The other removes it, with its sampling and analysis methods, from the technical guidance on applying those limits. Both are planned for February 2027 and would apply on the day of issue. Diethyl phthalate would therefore leave the exposure rules well before the new substances enter the labeling duty.
Comment process
The ministry accepts comments in Japanese only, with reasons, through the e-Gov portal, by email or by post. The ministry's cover notice says it will not answer individual comments.