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Guidance for the Implementation of China 2015 Inventory of Hazardous Chemicals (Trial)
Article 3. An enterprise who sells a hazardous chemical listed in the Inventory after changing the substance state should acquire Hazardous Chemicals Operation Permit.
The state of the substance refers to the gas, liquid or solid state of matter. This article further supplements the requirement set forth in Article 37, SAWS Order 55: If a purchased hazardous chemical will be resold before treated with such processes as split charging, refilling or dilution with a non-hazardous chemical solvent shall still be considered as subject to this regulation and the reseller must apply for the Permit.
Article 5. A chemical is regarded as a hazardous chemical and subject to hazardous chemical management if the major compositions are listed in the Inventory, and the sum of their mass fractions or volume fractions is no less than 70% (unless it is determined not eligible for the hazardous chemical determination principles after hazard identification). Work safety administrations should indicate the trade name and the major compositions for mixtures when issuing relevant safety administrative permits.
The term “major compositions” is not defined in the Implementation Guidance and may be subject to interpretations by local work safety administrations or chemical registration offices. The possible meanings of “major compositions” are shown in the following table:
Judgment | Further question |
Compositions which account for a large proportion of the product | The threshold is not defined. It’s difficult to assign a specific value. |
Compositions which contribute to the overall hazards of the product | The contribution to heath/environmental hazards could be assessed by comparing with the cut-off values set in the classification standards. However, it is difficult to assess the contribution to physical hazards. |
Major functional compositions which affect the performance of the product | Only in rare cases will the manufacturer disclose the full composition information to the traders. Therefore it’s difficult for importers/exporters to make a judgment. |
Intentionally added compositions, or compositions other than the impurities | Usually the impurities exist at a low level. The physical hazards may be ignorable, but the health and/or environmental hazards may not. |
If we don’t define the “major components”, the article can simply be interpreted as follows: A chemical is regarded as a hazardous chemical subject to the administrative licensing as long as it contains ingredients listed in the Inventory and the summation of their contents is equal to or more than 70% (w/w or v/v).
There is certainly a high potential for error when applying the 70% threshold, therefore, the hazard identification functions as a second and the decisive mechanism to determine the exact hazard properties of the chemical and generate or verify the data for classification. If the chemical doesn’t fall into any of the 81 hazard categories adopted by the Inventory, the manufacturers, usurers and operators are exempted from the licensing of the work safety administrations.
Note that hazardous chemicals subject to administrative licensing also require hazchem registration. In case of any data gap for registration, hazard identification needs to be carried out as well.
Article 6. For a hazardous chemical of which the major compositions are listed in the Inventory, and the sum of their mass fractions or volume fractions is less than 70% or the hazard properties have not yet been determined, the manufacturers and importers should carry out hazard identification in accordance with Measures on the Management of Physical Hazard Identification and Classification for Chemicals （SAWS Order 60）and other relevant regulations. For those determined to meet the hazardous chemical determination principles after identification, hazardous chemical registration should be carried out in accordance with Measures for the Administration of Hazardous Chemicals Registration (SAWS Order 53), while relevant safety administrative permits are not required.
This article complements the preceding article to clarify the industries’ obligations for chemicals containing ingredients included in the Inventory and existing at a proportion less than 70% (w/w or v/v) in total.
Note that according to SAWS Order 60, even if a chemical doesn’t contain any ingredient listed in the Inventory, it is subject to physical hazard identification as long as its hazard properties are unknown. (For more latest information please go to: Navigator of the Physical Hazard Identification and Classification of Chemicals under China SAWS Order 60)
Article 7. A chemical falls under Entry No. 2828 of the Inventory as long as it meets the flashpoint criteria. For convenience, some examples are provided in the Classification Information Sheet of Hazardous Chemicals. The listed coating and paint products are determined based on the film formers. For example, entry “phenolic resin paints (coatings)” refers to varies paints and coatings using phenolic resin, modified phenolic resin, etc. as the film formers. The corresponding film formers of paints and coatings can be referenced in GB/T 2705-2003: Classification and Nomenclature for Coating Products. Adhesives are determined based on the viscous materials. For example, entry “phenolic resin adhesives” refers to various adhesives using phenolic resin, resorcinol formaldehyde resin, etc. as viscous materials. The corresponding viscous materials of adhesives can be referenced in GB/T 13553-1996: Classification of Adhesives.
The Classification Information Sheet of Hazardous Chemicals lists 88 kinds of chemical products under Entry No.2828 of the Inventory, which are respectively classified to the following 3 categories:
Flammable liquids, Cat. 1 (Flash point＜23℃, and initial boiling point≤35℃)
Flammable liquids, Cat. 2 (Flash point＜23℃, and initial boiling point＞35℃)
Flammable liquids, Cat. 3 (23℃≤Flash point≤60℃)
* Liquids with a flash point of (35℃, 60℃] are not included if negative results have been obtained in the sustained combustibility test (Annotation 3, Classification Information Sheet of Hazardous Chemicals)
The other hazard classification results are left to be decided according the actual compositions.
Article 9. Based on the hazardous chemical classification information provided in the Classification Information Sheet of Hazardous Chemicals, manufactures and importers of hazardous chemicals shall determine the hazard statements, signal words, pictograms and precautionary statements for relevant chemicals in accordance with the Rules for Classification and Labelling of Chemicals (GB 30000.2-2013 ~ GB 30000.29-2013 series standards), GB 15258-2009: General Rules for Preparation of Precautionary Label for Chemicals and other national standards, compile or update chemical information registries including safety data sheets for chemicals (SDS) and precautionary labels, and fulfill chemical hazard information delivery and communication.
This article concerns the requirement for hazard communication of hazardous chemicals, which is also referred as China GHS-related obligations. The latest and effective national standards are shown in the following table:
Subject | Standards | Remark |
Classification | GB 13690-2009: General Rules for Preparation of Precautionary Label for Chemicals | To be replaced by GB 30000.1-201?, which is not yet finalized |
GB 30000.2-2013 ~ GB 30000.29-2013: Rules for Classification and Labelling of Chemicals | Corresponding to 28 hazard categories, and in line with UN GHS Rev.4 | |
Labeling | GB 15258-2009: General rules for preparation of precautionary label for chemicals | Allocation of label elements, contents, sizes, use of labels, etc. |
GB 30000.2-2013 ~ GB 30000.29-2013: Rules for Classification and Labelling of Chemicals | Assignment of label elements according to specific hazard classes and categories | |
GB 30000.30-201?: Rules for Classification and Labelling of Chemicals – Part 30: Work Safety Warning Signs | Not yet finalized, may be based on AQ 3014-2013 | |
GB XXXXX (probably GB 30000.31-201?): Rules for Classification and Labelling of Chemicals – Part 31: Labeling of Consumer Products | In progress, details not revealed | |
SDS | GB/T 16483-2008: Safety data sheet for chemical products – Content and order of sections | An SDS should comply with both standards. |
| GB/T 17519-2013: Guidance on the Compilation of Safety Data Sheet for Chemical Products |
Article 10. In terms of transporting hazardous chemicals, relevant regulations issued by the transport, railway, civil aviation, etc. authorities should be adhered to.
The majority of the chemicals in the Inventory are dangerous goods for transport. Companies can refer to the following lists for transport information
GB 6944-2012: Classification and Code of Dangerous Goods
GB 12268-2012: List of Dangerous Goods
List of Hazardous Chemicals Prohibited from Inland Waterway Transport (2015 Trial Version)
About the Author
Mr. Sun is a senior regualtory consultant of REACH24H Consulting Group China. He is extremely experienced in chemical classification, labeling and compiling SDS in accordance with the requirements of China GHS. He regularly runs training programs on China GHS and hazardous chemical regulations for the international companies such as Würth Group, Vaillant GmbH, Coloplast A/S, Cardolite Corporation. Currently his focus is on hazardous chemical regulations in China, mainly the Regulations on the Control over Safety of Hazardous Chemicals" (Decree 591).
