Hazardous chemical reagent classification, labelling, packaging and SDS requirements need to consider China GHS.
On 20 April 2012, China’s Standardization Administration (SAC) notified to the Committee on Technical Barriers to Trade under World Trade Organization a draft national standard on chemical reagent packaging and marking.
This draft contains 11 chapters and 2 normative annexes. Chapters 5, 6, 7, 8, 9 and 10 are mandatory; the rest are recommended. Mandatory contents of the proposal include the technical requirements for packaging materials of chemical reagent, basic requirement for product packaging, technical requirements for packaging and marks, as well as check and acceptance of packaging.
In general, chemical reagents, non hazardous or hazardous, are viewed in the control span of China GHS in terms of the rulings on SDS, classification and labelling. There are more extra labeling and packaging requirements for chemical reagents, such as information on molecular weight, molecular formula, quality grade, technical specification, net content and etc. on the product label, and the information on gross weight, unit of package, production date and batch number and transportation indication (shipping mark), etc. on the outer package.
It is noteworthy that this draft has highlighted differentiated transport packaging requirements for general chemical reagents and hazardous chemical reagents. Non hazardous chemical reagents apply to the general principles of Chapter 3, GB/T 9174-2008, and should fulfill the performance tests specified in Chapter 6 of GB/T 9174-2008. But if the reagent falls into the scope of hazardous chemicals, the product must be classified according to GB 13690, China’s mandatory national standard on classification and hazard communication of chemicals, and its relevant performance test for transport package must be in compliance with GB 12463.
For chemical reagent packaging, it clearly states that outer package containers must keep a China GHS SDS in line with GB/T 16483, China’s most important rules on writing safety data sheet, in addition to the manufacturer certificate or a product packing list including information on employee number, company name, company address, telephone and postal code, etc.
In product labelling, for hazardous chemical reagents, product manufacturers, users and distributors must supply a China GHS style label based on GB 13690, supply information on brief physical-chemical properties, signal wording and precautionary statements, etc. that are in line with GB 15258, and simultaneously mark the label with some caution like “please request a SDS for the product manufacturer”.
Outer package marks also specifies the requirement of labelling, attaching or hanging a clear-cut mark in line with GB 13690 if the concerned reagent products belongs to hazardous chemicals.
The draft standard, coded temporarily as GB 15346-201X, is expected to replace the old version, GB 15346-1994, and enter into force in 6 months after its adoption by the WTO Secretariat which shall be in 90 days as of its notification.
