China GHS - Introduction, Updates and technical Know-How on Classification, SDS, Labeling and Packaging
GHS, which stands for “Globally Harmonized System”, is a hazardous chemicals management system that addresses issues such as classification, Safety Data Sheet, labeling and packaging of hazardous chemicals. It was first proposed in the UN Sustainable Conference (WSSD) in Johannesburg, 2002, promising easier communication of hazards posed by chemicals and ultimately, protection of human health, environment and trade facilitation.
The UN GHS is not a formal treaty, but a non-legally binding international agreement instead. Therefore, different countries or trading blocks must create local/national legislation to implement GHS. China GHS draws its origin from the UN GHS. However, there exist differences between them. The full-scale implementation of China GHS is expected in the early 2012.
China GHS Timeline
Contents
Part I Introduction
- Relevant Competent Authorities
- Regulatory Framework
Part II Technical Know-How
- C&L Inventory
- Obligations under China GHS
- Obligation 1 -- Classification
- Obligation 2 -- SDS
- Obligation 3 -- Labeling & Packaging
- Obligation 4 -- Dangerous Chemicals Registration
- Obligation 5 -- The "Permit"
- Obligation 6 -- Emergency Telephone Number
Part III Prospective Development (To be updated)
Part I. 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 on dangerous substance 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.
Part II. Technical Know-How
- C&L Inventory
- Self-classification based on your own hazardous data, according to the national standards (GB 20567~GB 20602).
- Entrust the NRCC of SAWS to do the classification.
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.
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
- Obligation 1--Classification
Classification is one of the main components in the chemical management system. Correct classification provides the basis for the compliance of SDS, labeling and registration, etc.
GB 13690-2009 “General rule for classification and hazard communication of chemicals” (Mandatory) provides general classification information.
26 corresponding national standards (GB 20567~GB 20602), revised from the 2nd UN GHS, specify classification rules for 26 categories of hazards. Among the 26 hazards categories, there are 16 physical hazards, 9 human health hazards and 1 environmental hazard. Note: The aspiration hazard is yet to be released.
GB/T 24744-2009 “Classification and hazard pictograms for chemicals-General Specification”, lists the complete sub-categories of 26 hazard classifications and their corresponding pictograms, signal word and hazard statements.
- Obligation 2--Safety Data Sheet (SDS)
Safety Data Sheet is another main component of hazardous chemicals management.
GBT16483-2008 “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/English)
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.
Note: For detailed differences between SDS under China REACH and EU CLP or UN GHS, please make sure you talk to the regulatory specialist from REACH24h!
- Obligation 3--Labeling &Packaging
GB15258-2009 “General rules for preparation of precautionary label for chemicals” is the core standard for labeling, which specifies:
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.
- Obligation 4—Dangerous Chemical Registration
“Measures on Registration Management of Dangerous Chemicals (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:
Classification and Labeling information
Physical and Chemical properties
Main Uses
Hazard Properties
Safety requirements on storage, use and transportation
Emergency disposal measures
Read the NRCC annual report on the dangerous chemicals registration
- Obligation 5— 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.
- Obligation 6—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.
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.
- Obligation 1--Classification
Part III. Prospective Development (To be updated)
REACH24H China GHS Services
- Free GHS consultation
- Re-classification of substances and mixtures according to China GHS
- Preparation of label according to China GHS
- Preparation of China GHS - compliant SDS
- SDS Translation with specialized SDS software, guarantee quality and delivery
- Update your SDS authoring software, especially on China GHS
- -- Preparation of formats of SDS and label according to China GHS
- -- Providing Chinese national standard data sources for preparation of SDS
- --Classification of China GHS
- --Training of SDS and label making under China GHS
- --Providing the latest Chinese national standards and relevant lists
- --Review China SDS wording
- --Consultation of implement of GHS in China and other countries
More about China GHS
