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Contents
Companies in the hazardous chemicals industry should expect to be involved in obligations on various levels under China GHS, considering its multi-level regulatory system. Several key obligations are listed as follows.
China GHS Timeline
Introduction
China GHS is implemented through a complex-regulatory system, considering over ten Ministries/Departments and a number of regulation/measures/national standards being involved.
Relevant Competent Authorities
Ministry of Industry and Information Technology is the primary coordinating department. Other participating departments include State Administration of Work Safety (SAWS), Ministry of Environmental Protection (MEP), etc. National Registration Centre for Chemicals (NRCC) of SAWS is mainly responsible for implementing GHS.
Regulatory Framework
The entire China GHS regulatory system can be viewed in the diagram below. Generally, there are three levels arranged in order of decreasing legislative power.
The top administrative law, known as the revised “Regulations on Control over Safety of Hazardous Chemical” (Decree No. 591), is the primary legislative piece. Decree No.591 has replaced the original regulation (Decree No. 344) since Dec 1st, 2011.
The medium level consists of:
“Measures for the Administration of Hazardous Chemicals Registration” which is being revised from the original 2002 version, according to which all the hazardous chemicals shall be registered to NRCC of SAWS in the future.
Other measures regulating the manufacturing, storage, uses, transportation of hazardous chemicals.
The bottom level lists national standards (GB or GB/T documents), representing the concrete rules/guidelines for classification, labeling, updating SDS, etc.
C&L Inventory
The inventory of hazardous chemicals (or “C&L Inventory”) is compiled from both the “List of dangerous chemicals” (2002 version) and “List of highly toxic chemicals” (2002 version) and other chemical substances considered as hazardous. The figure below visualizes the scope of the C&L Inventory.
Chemicals listed in the C&L inventory are expected to comply with China GHS. Unfortunately, the decision is not that straightforward currently since the revised C&L inventory is not yet released (expected in early 2012).
For chemicals unlisted, there are two options to determine your responsibility under China GHS
Self-classification based on your own hazardous data, according to the national standards (GB 20576-20602).
Entrust the NRCC of SAWS to do the classification.
If the chemicals are determined to be hazardous by either of the two approaches above, the chemicals will have to comply with the China GHS even if they are not listed in the C&L inventory.
Updates: Among the hazardous chemicals expected to be listed in the C&L Inventory, around 4,406 chemicals were classified base on GHS criteria, there are still 3,331 chemicals remain unclassified yet.
Obligations under China GHS
Classification
Perform classification on chemicals according to the 26 national standards, GB 20576-20599 and GB 20601-20602.
Safety Data Sheet (SDS)
GB/T16483-2008 “Safety Data Sheet for chemical products- Content and order of sections” provides guidelines for SDS preparation. This national standard entered into force from 1st Feb, 2009. The SDS implementation is realized through the dangerous chemicals registration (Obligation 4). For foreign companies, SDS will also be inspected by the Customs.
(Sample of SDS in Chinese)
Although the layout of SDS under China GHS is similar to that under EU CLP, difference still exists between them. Therefore, a direct translation from other countries’ SDS/MSDS to SDS under China GHS is not recommended.
Labeling &Packaging
Sequence of hazard information: 1. Physical; 2. human health; 3. Environment.
For simplified labeling, precautionary measures could be left out on the container < 100 ml
Label size
Printing requirements of the label
Usage of the label
Click here for a sample of regular and simplified label.
GB15258-2009 was implemented from 1st May, 2010. The grace period is from 1st May, 2010 to 1st May, 2011. Therefore, from 1st May, 2011, chemicals unable to provide label in line with China GHS will have a chance of being withheld by the Customs.
GB/T 22234-2008 “Labeling of chemicals based on GHS” lists all the possible hazard categories corresponding to one pictogram in the table form.
GB 190-2009 “Packing symbol of dangerous goods” (mandatory) specifies the pictogram, size, color and usage of the packing symbol for corresponding categories of dangerous goods.
Dangerous Chemical Registration
“Measures for the Administration of Hazardous Chemicals Registration (Decree No.35)” requires all hazardous substances/mixtures should be registered to NRCC-SAWS. Currently, registration serves as the main route to ensure the implementation of China GHS.
Information required for China GHS registration include:
Read the NRCC annual report on the dangerous chemicals registration
Classification and Labeling information
Physical and Chemical properties
Main Uses
Hazard Properties
Safety requirements on storage, use and transportation
Emergency disposal measures
Apply to the “Permit”
Companies involved in the hazardous chemicals industry should apply for the permit corresponding to their role in the supply chain. i.e. manufacturers should apply for the manufacturing permit according to the “Measures on the Manufacturing” and companies which use hazardous chemicals should go with the hazardous chemical safe use permit according to the “Measures on the Safe Use”, etc.
Emergency Telephone Number
Emergency telephone number is a unique feature under China GHS. Companies should include an appropriate emergency telephone number on the SDS, label and registration documents. Several requirements on the emergency telephone number have to be met, including
24/7 available
Within the territory of China
Professional work staff responding
Please note that the obligations discussed above does not make the complete list, detailed consultation with the regulatory specialists from the REACH24h is strongly recommended.
