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Shanghai Strengthening China GHS Implementation

Shanghai has been strengthening implementation of China GHS since autumn 2011 and companies engaged in trans-national trading of hazardous chemicals are reminded of the differences between labels for dangerous goods on water transport and the China GHS-compliant labels.

On 29 August, the Municipal Transport and Port Authority of Shanghai (MTPA) issued a notice that clarified the distinct requirement of precautionary labeling for chemicals in line with GB 15258-2009 (General rules for preparation of precautionary label for chemicals), one of the main technical supporting documents for Decree 591 (Regulations on the Control over Safety of Hazardous Chemicals in China). GB 15258 was put into effect on the first day of May 2011 and Decree 591 will take effect next month.

The MTPA notice stressed that chemicals under the GHS labeling provisions are more extensive in scope than those specified in the field of dangerous goods on water transport. Shipping companies and forwarder businesses, however, should make it clear that while GHS specifies the classification information on chemicals “their port and loading operations concerned with dangerous chemicals still apply to Chinese GB 12268-2005 (List of Dangerous Goods) and IMDG CODE (International Maritime Dangerous Goods Code)”.

Both companies and different levels of port administrative authorities are asked to carry out professional trainings on GHS-related basics, which include this precautionary labeling rules and MSDS writing rules (GB/T 16483-2008).

Currently leading Chinese shipping companies have been receiving notices from various foreign trade organizations. Yet corporate confusion still exists in many aspects regarding the scope of chemicals subject to China GHS labeling, design of a China GHS-compliant label and its usage, differentiation between GHS label and the shipping mark under IMDG CODE, etc.

To improve understanding on the labeling requirements under China GHS, REACH24H here presents a brief analysis on some key points in GB 15258:

Container or package container (L)

Label size (mm x mm)

≤0.1

simplified label

>0.1~≤3

50 x 75

>3~≤50

75 x 100

>50~≤500

100 x 150

>500~≤1000

150 x 200

>1000

200 x 300

  • A typical China GHS label may consist of 9 main parts: product identifier, pictogram, signal word, symbol, hazard statement, precautionary statement, supplier information, emergency response telephone, and reference suggestion (suggesting reference to its MSDS).

  • Emergency response telephone number that is available 24 hours should be supplied by the chemical producer or his appointed agent. Imported chemicals must have at least one Chinese based 24-h emergency telephone number.

  • Simplified labels: for small package weighing under 100 mL, companies are allowed to provide only a simplified label, which displays fewer label elements, including product identifier, pictogram, signal word, hazard statement, emergency response telephone, supplier information and reference suggestion.

  • In case multi-hazards exist, the signal word has to appear either “Danger” or “Warning”.

  • Pictogram colors: black symbols with white background and red diamond-shaped pictogram frames. If used only inside Chinese mainland, the frame could be in black.

  • Label size: minimum dimensions for varying containers are shown as the below table:

  • Label printing: The label should be inside a black border frame of 1 mm in breadth. The spacing outside the border frame should be 3 mm in breadth.

  • Usage: When used accompanying a shipping mark, the shipping mark should be placed on the opposite side of the container where the precautionary label is attached. The shipping mark can also be placed near the label on the product package and in this case if the pictogram on the label is identical with the one on the shipping mark, the pictogram on the label should be deleted.

  • For composite containers: It is obligatory to attach labels to the inner package and shipping pictograms to the outer package. If it is unnecessary to apply any shipping symbol, the precautionary label should be attached to the outer package instead.

A sample of China GHS precautionary label

A sample of simplified label

 

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