MSDS Notice 2026-26: foreign-language warning labels and mixture information
Adding another language retains the Korean-label rule
MOEL Notice No. 2026-26 amended the criteria for chemical classification, labelling and material safety data sheets, taking effect on 2026-04-24. It addresses added or parallel warning labels in a language foreign workers understand, statements and codes, regulatory information for mixtures, keeping information current, and supply through the KOSHA system.
The amendment does not permit replacement of Korean labels with foreign-language-only labels. The Korean-label rule in the main text of Article 5(1) remains. Korean and another language could already appear together on the same label. The amendment adds a proviso allowing an additional label or parallel text in a language understood by foreign workers.
Warning labels and material safety data sheets (MSDS) convey different amounts of information. Labels identify hazards on containers and packaging; an MSDS provides hazard, handling, emergency and regulatory information. Translating one does not remove the requirements to prepare, display or supply the other.
Purpose of the amendment and retained duties
The official amendment reasons identify clarification of the MSDS preparation scope and a basis for additional foreign-language warning labels as improvements to operational gaps. The changes concern who prepares information and how it reaches workers and trading partners, rather than merely changing chemical names or terminology.
Preparation and submission by manufacturers or importers under Act Article 110, supply to transferees or recipients under Article 111, and workplace access and training under Article 114 are existing statutory roles. Container and packaging warnings under Article 115 were not first created by this notice. Separating amended wording from continuing duties helps prevent omissions and duplication.
The person labelling a container, the document supplier and the workplace user can be different. A manufacturer’s submission and a supplier’s provision to a trading partner have different recipients. The presence of a document in the KOSHA system is not the same as easy access for workers at their workplace.
Distinguish additions from existing provisions
Article 6-2(6) allows code numbers alongside hazard and precautionary statements. It does not allow the statements to be replaced by codes alone. Even when a short code is prominent, the sentence conveying the hazard or precaution still needs to remain.
Article 11(11) specifies regulatory information applying to the mixture as a whole. Paragraph 12 requires continuing maintenance consistent with current scientific and technical information and applicable legislation. Article 13 includes the KOSHA system in electronic supply channels. Confirmation of receipt is a retained condition, not a newly introduced requirement.
Figure 1 separates the roles of language and codes. It is not a substitute product label with actual pictograms or specific hazard statements. The classification and label content of the substance used at work need to be checked against the relevant documents and legal text.
| Provision | Previously | 2026-26 amendment |
|---|---|---|
| Article 5(1) | Korean labels; foreign text on the same label already allowed | Proviso for added or parallel labels in a language foreign workers understand |
| Article 6-2(6) | No corresponding statement/code provision | Statements retained; accompanying code numbers permitted |
| Article 11(11) and (12) | Diligent preparation and other rules | Mixture-wide regulatory status and continuing currency specified |
| Article 13(1)2 | Supply by information network or electronic document | KOSHA system expressly included; receipt confirmation retained |
Article 6-2(6) — Korean legal text
유해ㆍ위험문구 및 예방조치 문구는 해당 문구를 표시하되 코드 번호를 함께 표시할 수 있다.- 1 Primary languageRetain the required Korean wording while adding the necessary foreign language.
- 2 Foreign workerscommunicate the relevant information in a language the foreign worker understands.
- 3 Statements and codesboth hazard and precautionary statements must display the wording; codes may accompany it.
- 4 Codes alonecodes cannot replace either hazard or precautionary statements.
- 5 ExceptionsExport and testing/research conditions have separate provisosCheck foreign-language exceptions and supplementary wording for foreign workers separately.
Foreign-worker labels and the testing or research exception
An additional label for foreign workers must use a language they understand. Choosing a language solely from nationality, or assuming that everyone understands available English material, misses that communication condition. Whether to add a separate label or include parallel text requires consideration of legibility and the conditions in the notice.
Article 5(2) provides a separate exception for laboratory reagents used for testing or research and finished products stored or transported for export. The former proviso was moved into a paragraph; foreign-worker status was not added to that exception. Chemicals used in an ordinary workplace cannot simply be treated as laboratory reagents.
The language of the MSDS itself is governed by Article 11. Korean is the default, while proper names such as chemical names and foreign institutions may be written in English. Permission to add a foreign language to a warning label under Article 5 does not establish that the entire MSDS can remain untranslated. Language conditions need to be separated by document type.
Article 5(1) proviso — Korean legal text
물질안전보건자료대상물질을 취급하는 근로자가 대한민국 국적을 가지지 않은 사람으로서 외국인근로자에 해당하는 경우에는 외국인근로자가 이해할 수 있는 언어로 작성된 경고표지를 추가로 작성하여 부착하거나 전단에 따른 경고표지에 병기하여 부착할 수 있다.Ingredient fields and regulation of the whole mixture
A mixture MSDS contains fields for individual ingredient names and concentrations and a separate regulatory-information field. Article 11(11) requires the regulations applying to the mixture as a whole to be stated regardless of whether ingredient names and concentrations are entered. The absence of a name from the ingredient field does not end the regulatory-information assessment.
Regulation of the mixture as a whole also does not mean that every regulation applies to every mixture. The entry must reflect the actual composition, hazards and scope of the relevant legislation. Avoid copying a single ingredient’s regulatory statement to the finished product without assessment, or listing ingredients while leaving the product-level assessment empty.
When reviewing an MSDS for a newly received product, first match the product and supplier, then consider what the ingredient and regulatory fields each describe. This is a document-review example, not a new statutory form. Concentration thresholds and classification limits require the relevant annex and product data rather than an invented universal number.
Article 11(11) — Korean legal text
제10조제1항제15호에 따라 물질안전보건자료에 혼합물의 법적규제 현황을 기재하는 경우 제10조제1항제3호에 따른 개별 구성성분의 명칭 및 함유량 기재 여부와 관계없이 혼합물 전체로서 적용되는 법령상 규제사항을 기재하여야 한다.Current information and supplying revised versions
Continuing maintenance includes consistency with legislation as well as scientific and technical information. Retaining the document originally prepared differs from keeping its contents current. New hazard information or a change in applicable law calls for examination of which MSDS fields are affected.
Article 11(12) does not prescribe an annual or other fixed interval for blanket rewriting. Simply placing a new date on the document is not a substitute for currency. The relevant question is how product information or applicable conditions have changed and whether the necessary content is reflected.
- 1 ProductCheck the legal regulatory status of the mixture as a whole alongside its component information.
- 2 Preparation dataassess it with the evidence needed for the mixture’s status.
- 3 Current informationconnect new hazard information with the contents of the maintained SDS.
- 4 Supply channelIncludes transmission through the KOSHA systemdistinguish submission to KOSHA from supplying the document to a trading partner.
- 5 Receiptchanging the transmission route does not remove the condition to confirm receipt.
Act Article 111 requires manufacturers and importers to supply the revised material referred to in Article 110(3) to recipients. An intermediary receiving revised material must pass it to the next recipient. Connecting document maintenance with distribution helps prevent continued workplace reliance on an older version. Figure 2 separates the subjects checked during preparation, maintenance and supply.
Article 11(12) — Korean legal text
물질안전보건자료를 작성할 때에는 취급근로자의 건강보호 목적에 맞도록 성실하게 작성하여야 하고, 기재된 내용이 최신의 과학적ㆍ기술적 정보 및 관련 법령에 부합하도록 지속적으로 관리하여야 한다.
Supply through KOSHA and confirmation of receipt
Article 13(1)2 expressly includes the KOSHA MSDS system among information-network and electronic-document supply routes. It does not remove earlier electronic routes or require use of only that system. Registered mail remains an option, and electronic supply is subject to the condition of directly attaching or storing the document for provision.
The requirement to confirm the recipient’s receipt remains. Uploading a document and the trading partner receiving it are different facts. A claim that sending any external link always completes the supply duty does not match this wording. The chosen method needs to meet both the permitted route and the receipt-confirmation condition.
Enforcement Rule Article 160(2) allows omission of additional supply when the same substance is repeatedly provided to the same recipient and the MSDS has not changed, except when the recipient requests it. An unchanged product name does not excuse withholding revised or requested material. This repeated-supply provision was also not newly introduced by this notice.
Commencement on 2026-04-24 and an earlier notice’s transitional rule
The Addenda to Notice No. 2026-26 state that it takes effect on issuance. Even where addenda from earlier notices appear below the current text, their numbers and subjects need to be read separately. The earlier Annex 4 transitional rule under Notice No. 2025-50 must not be treated as a blanket deferral of the new notice.
The Addenda to Notice No. 2025-50 contain a separate rule allowing use of the earlier Annex 4 for documents prepared through 2026-06-30. That date does not defer every change in Notice No. 2026-26, such as foreign-language labels or continuing maintenance. Distinguish application of a form revision from commencement of preparation, labelling and supply rules.
Notice No. 2026-26, Addenda — Korean legal text
이 고시는 발령한 날부터 시행한다.Three document-review situations
When foreign workers join a task, review how to add an understood language while retaining the Korean label. Also check that names in the label and MSDS training identify the same substance. Adding a language does not itself confirm understanding; it needs to connect with workplace training and communication.
On receiving a label with added codes, check that the wording remains. Distinguish replacing sentences to save space from adding codes beside readable statements. Confirm the actual codes and dimensions from the relevant substance’s source material rather than imposing an invented universal label.
When a revised mixture MSDS arrives, review its regulatory information and changes, and connect the version available at work with the version sent to the next trading partner. Contents can change without a new file name. Storage location and checking the actual document contents are separate management subjects.
Duty holder and applicable provision
The applicable statutory provision depends on the role: manufacture or import, transfer or supply, or workplace handling. The option to add a foreign-language label is different from the underlying warning-label duty.
Administrative fine amounts and tiers for each violation are prescribed in the Occupational Safety and Health Act’s Enforcement Decree, Annex 35. This article does not reproduce the amounts; consult the original annex for the applicable amount.