For multi-constituent substances, illustrative examples of how Section 3 and Section 15 could look are given in the guidance.

The Japan Chemical Industry Association (JCIA) recently published a guidance to assist the industry in compilating SDSs according to the new requirements under the revised ISHL (news). The guidance, although not an official regulation, is considered of high value for reference since it was prepared in in-depth cooperation with the Ministry of Health, Labour and Welfare (MHLW).

This guidance provides templates especially on:

• Recommended uses as well as use restrictions
• Types of protective equipment to be used for the recommended uses
• Display and non-disclosure of ingredients concentration

In addition, detailed interpretation is given on issues regarding the regular update of SDS, the expanded delivery methods of SDS, and how to fill in SDS Section 2 if there is no GHS hazard classification or there have other hazards, e.g., dust explosion hazard.

Requirements Under Japan SDS and Revised ISHL

Japan’s SDS follows a 16-section format which is internationally agreed. However, according to the revised ISHL, from April 1, 2024, in principle a specific concentration shall be indicated on SDS, rather than concentration range. The current maximum width of 10% for indicating concentration range will be abolished and concentration range can apply only if the ingredient has concentration range due to force majeure. This new requirement has attracted widespread attention from the industry. To better clarify the requirement, illustrative examples of how Section 3 and Section 15 could look are given in the guidance for multi-constituent substances.

For example, for mixture A, the ingredients are listed below, as well as the content (%). Whether they are controlled substances under ISHL should be identified since it relates to if they apply to CBI protection.

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Reference Links

Japan Revises Rules for SDS and Labelling Under ISHL

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