JCR-Link: Japan Chemical Regulatory Consultant for North East Asian (Japanese, Chinese, Korean etc.) chemical regulations

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FAQ

MSDS

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Is MSDS in Japan required to be described in Japanese language under the relevant laws?

Poisonous and Deleterious Substance Control Law, PRTR Law and Industrial Safety and Health Law require to prepare MSDS in Japanese language. (As of Jan.8, 2011)

See legal grounds by visiting member FAQ page.

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Are Japanese Industrial Standards (JIS) in connection with GHS available in English?

Yes but not all.

We have three JIS that are prepared for the introduction of GHS: JISZ7250 (for MSDS), JISZ7251 (for Label), and JISZ7252 (for GHS Classification). Among those, JISZ7250 and JISZ7252 have been translated and are available in the Website of JSA Web Store. Please click the below URL..

(As of Jul. 28, 2010)

http://www.webstore.jsa.or.jp/webstore/Top/indexEn.jsp?lang=en

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Is MSDS required for articles under the relevant laws? (revised on Feb.2, 2012)

No. except the Industrial Safety and Health law

Legal grounds:
PRTR Law:
	Clause 1 of Article 5 and Article 6 under the Cabinet Order define the products, as below, that are excluded from the scope of this law. "Products which do not change its physical state to non solid states AND do not become to physical states of powder or granule during the handling process of business entities".
Industrial Safety and Health Law:
	This law does not distinguish articles from the other standard chemical substances. However, products (including articles) mainly used for consumer usages are exempt from MSDS requirements. No. I, 1, 3, C (は) of the Notice (Mar. 24, 2000, No.162) of the former Ministry of Labor defines the products, as below, that are exempt from MSDS requirement. "Products which do not change its physical state to non solid state AND do not become to physical states of powder or granule during labor's handling process"
Poisonous and Deleterious Substance Control Law:
	As of Aug. 2, 2010, this law only designates substances and preparations as poisonous and deleterious substances. In addition to this, FAQ which is posted on the website of the Ministry of Health and Welfare says articles, even they contains designated substances, are not recognized as preparation. Examples of article: equipment, instruments, tools, and equipment and/or instruments coated with paint of deleterious substance. Due to the above reason, at the moment, articles are not in the scope of this law, hence, MSDS is not required for articles now.

Confidential Business Information

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When exporting existing chemical substances (in CSCL inventory) to Japan do we need to disclose chemical information to the importers?

Yes,

For custom clearance, importers are obliged to indicate CSCL inventory number in invoice or in import document for all existing chemical substances in a product. Details including for the other types of chemical substances such as chemical substances for R&D uses are described in the notice for the custom clearance procedure for chemical substances related to the Chemical Substance Control Law (Mar.30, 2010, METI)

However, this requirement does not apply to chemical substances in articles, etc. that are not in the scope of "Chemical Substance" under the law.

Note: CSCL inventory = ENCS inventory = MITI inventory = METI inventory, CSCL stands for Chemical Substance Control Law