Magus International Legal Office

Chemical Management

Safety Data Sheet

In Japan, SDSs have been standardised in their description as the Japanese Industrial Standard JIS Z 7253, as a Japanese domestic standard. In addition, SDSs must also be prepared in accordance with the description guidelines in three other laws and regulations: Act on the Assessment of Releases of Specified Chemical Substances in the Environment and the Promotion of Management Improvement, Industrial Safety and Health Act, and Poisonous and Deleterious Substances Control Act. 

Japanese SDSs stipulate that confidential ingredients are not permitted in principle and that certain ingredients must be disclosed. In addition, English SDSs are not permitted in Japan and must be translated into Japanese. Furthermore, Japanese SDSs must indicate the Japanese law relevant to the chemical concerned.

Our firm translates the provided SDSs into Japanese, performs the legal research and prepares SDSs compliant with Japanese standards and Japanese law.

Chemical Substances in Japan

When selling chemical substances in Japan, it is necessary to comply with various laws, guidelines, and regulations. There are about 80 laws related to chemical substances in Japan alone.

Some chemical substances are subject to regulations even for research and development purposes in small quantities, some require export control when returned outside Japan, and some require reporting of emissions to the atmosphere by calculating natural evaporation.

Magus International Legal Office checks what laws and regulations you need to comply with in order to sell or use your chemical substances in Japan, and provides consulting services to ensure that you comply with them appropriately.

In addition, we also represent you in procedures with relevant government agencies such as Japan Customs, Ministry of Economy, Trade and Industry, Ministry of Health, Labour and Welfare, and Nuclear Regulation Authority.


FAQ

Q1 : After exporting glue to Japan, we received a call from our Japanese distributor saying that the glue has been stopped by Japanese customs and they are demanding disclosure of the ingredients. We do not want to disclose the ingredients of the glue to the Japanese distributor because they are trade secrets. What should I do?

A1 : When exporting glues or paints to Japan, Japanese customs may require disclosure of ingredients. Howeber, if you do not wish to disclose them to your Japanese distributor, we can act as your customs agent to clear customs on your behalf, without disclosing the confidential ingredients to your Japanese distributor.

Since we are a law firm, we are subject to a strict obligation of confidentiality under Japanese law, which carries a penalty of imprisonment if violated.


Q2 : Q1: Our company wants to export chemicals to Japan for sale. The only work we do in Japan is to sort the containers into smaller containers, and we do not perform any new chemical reactions or admixtures. Do we need to comply with any Japanese laws and regulations?

A2 : First, we will check whether or not an application based on the Act on the Regulation of Manufacture and Evaluation of Chemical Substances, Industrial Safety and Health Act, etc. is required for imported chemical substances. Some chemical substances may not be allowed into Japan.

Next, when the chemical substance is to be sold to a business in Japan, a Japanese-language SDS must be prepared in accordance with Japanese standards. The items to be legally described on the SDS vary depending on the chemical substance. In addition, 

In addition, if a chemical substance is designated as subject to the emissions reporting system under the Act on the Assessment of Releases of Specified Chemical Substances in the Environment and the Promotion of Management Improvement, you are obliged to calculate and report the amount of emissions depending on the amount handled. 

Furthermore, when chemical substances are returned to overseas factories due to problems such as defective products, inclusion of banned substances, or impurity, export control based on FEFTA is required.