Apparently yes. According to Herbert Bix:

[Hirohito] supported the policy of withholding a declaration of war against China and ratified and personally endorsed the decision to remove the constraints of international law on the treatment of Chinese prisoners of war s stated by the army vice chief of staff in a directive on August 5, 1937: "In the present situation, in order to wage total war in China, the empire will neither apply, nor act in accordance with, all the concrete articles of the Treaty Concerning the Laws and Customs of Land Warfare and Other Treaties Concerning the Laws and Regulations of Belligerency." The same notification advised staff officers in China to stop using the term "prisoner of war." Throughout the war in China the Japanese military captured tens of thousands of Chinese soldiers annually. Yet, at the war's end, when Japanese authorities claimed to have had in their possession scores of thousands of Western prisoners, they acknowledged having only fifty-six Chinese prisoners of war. [1]

Rotem Kowner also comments:

From the start of the [Second Sino-Japanese War] until its end more than eight years later, the Japanese government designated it an 'incident' (Shina jihen). Under this term, the conflict remained beyond the law of war, with terrible consequences for the treatment of Chinese POWs and non-combatants. In most cases, and despite orders against maltreatment, surrendered Chinese troops were not recognized as prisoners. They were denied the rights and laws relating to POWs according to contemporary conventions, to which neither of the belligerents was signatory. On many instances, the most notable of them is during the fighting over Nanjing in December 1937, large groups of surrendered Chinese soldiers were summarily executed on the spot, or soon after their surrender. Similarly, in later phases of the war, captured Chinese soldiers were considered 'bandits', and likewise executed on the spot. In times of respite, especially after 1940, when their labour was required and logistic impediments were minor, Chinese POWs were designated labourers (kajin rōmusha) and were given demanding physical tasks in China, Manchuria or Japan. Less common but nonetheless telling was the use of thousands of prisoners as guinea pigs in medical experiments with biological weapons, which invariably killed them. For these reasons, the low number of Chinese POWs in this conflict does not reflect its intensity. The Chinese authorities, both the nationalist forces and especially the communists, did not necessarily reciprocate towards the Japanese with equal treatment. A few thousands of Japanese POWs, the majority of them captured during the last two years of the war, underwent 're-education' programmes (developed by the Communists as early as in 1939) and by and large were repatriated to Japan after the war. During the war, there was a noticeable escalation in the Japanese regulation against desertion, and in some cases retrieved Japanese POWs were advised to commit suicide. In March 1941, the Japanese army in China instructed soldiers that on being taken prisoner their orders were to escape immediately or commit suicide. [2]

There are two things I should add to this. First, many of the prisoners who served as forced laborers died or became crippled while toiling in substandard conditions. Second, the Chinese Nationalists treated surrendered Japanese soldiers fairly well after the cessation of hostilities in 1945; by 1948, the government had successfully repatriated 2,020,345 soldiers and civilians back to Japan without major incident, though in the ensuing Civil War the Nationalists and Communists employed some 50,000 and 60,000 Japanese POWs, respectively, in their own forces. I hope you find this helpful! :)

[1] Herbert P. Bix, Hirohito and the Making of Modern Japan (New York: HarperCollins, 2000), 359f.

[2] Rotem Kowner, "Imperial Japan and Its POWs: The Dilemma of Humaneness and National Identity," in War and Militarism in Modern Japan: Issues of History and Identity, ed. Guy Podoler (Folkestone: Global Oriental, 2009), 88f.

Edit: If you're interested, I recently wrote a lengthy post of Japanese war crimes in China--link here.