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The 15th Chemical Regulatory Annual Conference (CRAC) took place in Shanghai from November 16-17, 2023, attracting over 430 participants from various countries and regions, including government agencies, representatives of international organizations, industry experts, and numerous enterprises. The conference discussions highlighted concerns from both domestic and overseas enterprises regarding the potential compliance burdens associated with the Hazchem QR code application in China.
Drawing from the experience of Guangdong's pilot project, many domestic enterprises that handle Hazchem outside Guangdong have proactively implemented internal management measures to ensure advanced compliance. However, Mr. Chen Jinhe, from the Ministry of Emergency Management (MEM), shared that the Hazchem QR code application is still in the pilot phase and has not been fully implemented nationwide. Pilot provinces and cities are currently promoting their own localized pilot projects to pave the way for fully implementing the “One enterprise, One chemical product, One QR code” policy. Each pilot province or city may have its own specific focus, leading to localized pilot projects with additional requirements, which results in an increase in compliance burden. Enterprises expressed the need for a more scientifically designed policy and emphasized the importance of cooperation, coordination, and communication among different government agencies and authorities in different areas.
In China, QR code is utilized to enhance digital and intelligent management in various aspects, not limited to Hazchem management. For example, the Ministry of Agriculture (MoA) requires a scannable QR code for pesticide label. A question raised by an attendee was whether an enterprise handling chemicals that are both pesticides and Hazchem would need to affix two separate QR codes. Currently, the answer is YES. However, positive news was shared at the conference by Mr. Xu Wei regarding the possibility of collaboration between the MEM and MoA to consolidate these two QR codes into a single QR code.
Mr. Xu Wei, from the Shanghai Emergency Management Bureau (SEMB), pointed out that the SEMB would cooperate with Shanghai Customs to develop the WHITELIST based on Shanghai’s pilot project for the Hazchem traceability code system. Importers who coordinate with overseas suppliers to obtain and affix the Hazchem traceability codes before road transport from ports will have the opportunity to be included in the WHITELIST. Once listed, these importers can enjoy exemptions from sample inspection and a decrease in the proportion of unpacking and inspection, thereby facilitating expedited customs clearance. Although overseas suppliers exporting Hazchem to China are currently not obligated to affix Hazchem QR codes, they are concerned about the potential shift in compliance burdens onto them.
*ChemLinked has published an article in this regard, please refer to: Shanghai to Pilot Hazchem Traceability Code in 2024.
To guide and assist enterprises in using the Hazchem QR codes, several supporting documents have been developed, some of which are to be revised or published. These include:
Regulations on the Administration of Hazardous Chemical Safety Information Codes (Trial)
It was drafted by MEM in early 2022 for comments in limited groups, not yet finalized.
GB 15258 General Rules for Preparation of Precautionary Label for Chemicals
It is planned to be revised to incorporate QR code requirements. However, there’s no specific timeline. Stakeholders are encouraged to provide their opinions for the revision.
T/CCSAS 0XX—202X: Technical specification for coding and labeling of hazardous chemical
It is expected to be adopted and released in the near future, shared by Mr. Chen. This group standard emphasizes the importance of “uniqueness” for the Hazchem QR code. Enterprises can combine the Hazchem QR code (generated via the Hazardous Chemical Registration Comprehensive Service System) with their own internal management code to ensure compliance.
**Our company, REACH24H Consulting Group, is deeply involved in the development of this group standard. The English translation will be available soon.
As pilot projects are being promoted or implemented in different provinces and cities, careful consideration and coordination are needed to ensure streamlined compliance processes. It is crucial to address the concerns of domestic enterprises and overseas suppliers to maintain a harmonious and effective implementation of the Hazchem QR code.
Our company REACH24H Consulting Group, in collaboration with local authorities, continues to be deeply involved in the Hazchem QR code pilot projects in certain provinces and cities. If you have any feedback on the Hazchem QR code application, or would like to gain a better understanding of your obligations, please feel free to contact us.
