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• Cosmetics and Cosmetic Ingredient
• Occupational Exposure Limits & Protection

Classification, Labeling, Packaging of Chemicals and SDS in China – China GHS

Updated in Feb 2012

"Globally Harmonized System of Classification and Labeling of Chemicals (GHS)" is a system created by UN to address the classification of chemicals by types of hazard and harmonize hazard communication elements, including labels and safety data sheets. It aims at providing a basis for harmonization of rules and regulations on chemicals at national, regional and worldwide level, an important factor also for trade facilitation.

As an international agreement GHS is non-legally binding in the member countries of United Nations.  Thus many countries and regions have published their own regulations or standards to implement GHS. For example, the GHS criteria were introduced into Europe via the Regulation (EC) No 1272/2008 on the Classification, Labeling and Packaging of substances and mixtures (CLP) in 2008.

China is one of many countries that have agreed to implement GHS. Chinese government has published several compulsory national standards (starting with GB) and recommended national standards (starting with GB/T) between 2006 and 2009. All of those standards have incorporated GHS criteria and entered into force in recent years.

The Chinese government firstly published 26 national standards called the “Safety rules for classification, precautionary labeling and precautionary statements of chemicals (GB 20576 ~ GB 20602-2006)” in 2006.  All 26 standards are directly transferred from UN GHS 1st edition(2003). 26 national standards represent 26 categories of hazards (No aspiration hazard is available.)

Later the National Technical Committee on Dangerous Chemicals Management of Standardization Administration of China (SAC/TC251) released 5 more national standards based on the safety rules GB20576 to 20602.

Companies selling chemicals to China and chemical companies in China are required to adopt these standards to classify, label and package chemicals as well as prepare safety data sheets in accordance with the requirements of GHS as from 1 May 2011.

NEW! The 4th revised version of UN GHS was released on 8 Sept 2011. CIRS has summarized the differences between the 4th revised UN GHS, CLP regulation and China GHS. For more info, please click here.

China is currently revising its GHS standards to be aligned with the latest edition of UN GHS. Those new GHS classification standards might be available next year.

Classification Standards

China’s mandatory national classification standard is "General rules for classification and hazard communication of chemicals" (GB 13690-2009), which came into force on 1 May 2010. It refers to the 26 national standards that were issued in 2006. The transition period is between 1 May 2010 and 1 May 2011. 

After 1 May 2011, it is mandatory for companies to classify chemical hazards in accordance with the requirements of GHS. Chemical hazard communication rules are also revised to be consistent with the requirements of GHS.

Note 1: Because UN-GHS is frequently updated, China GHS is slightly different from UN GHS or CLP(the difference is listed below). There is no need to pay other companies to get an English copy of Chinese national standards as UN GHS 1st Edition is the best translation and it is free.

Note 2: Because GB 13690-2009 is just a technical standard and there is no enforcement and penalties in this standard (unlike law or regulation), there might be no penalties for companies who fail to implement this standard between 1 May 2011 and 1 Dec 2011.

Note 3: Companies shall prepare for China GHS and act now before the Regulations on Safe Management of Hazardous Chemicals in China enter into force on 1 Dec 2011 to avoid possible penalties.

Note 4: Ordinary chemicals are still affected by China GHS. However, only failure to classify and label hazardous chemicals in accordance with national standards will incur penalties from 1 Dec 2011.

Labeling and Packaging Standards

China released 3 national standards related to the labeling and packaging of chemical products in line with GHS in 2008 and 2009.

The first mandatory national labeling standard (GB 15258-2009) – “General rules for preparation of precautionary label for chemicals” came into force on 1 May 2010. Examples of precautionary labels, transport symbols, and precautionary statements for different categories of chemicals are given in this standard. The transition period is also between 1 May 2010 and 1 May 2011. There are some differences between this standard and CLP regulation.

• Black frame of a pictogram is also acceptable;
• Simplified label is available for volume < 0.1L;
• No requirement on the minimum size of a pictogram;
• There is no limit of 6 p-statements;
• Emergeny number on the label must be a domestic 24h emergency telephone number.

The second mandatory national standard (GB 190-2009) - “Packaging Labels for Dangerous goods" is based the 15th revised edition of the UN recommendations on the Transport of Dangerous Goods. This standard specifies the requirements of pictogram, label size, colour and packaging of hazardous goods.  This standard also came into force on 1 May 2010.

 The third labeling standard is “Labeling of Chemicals Based on GHS” (GB/T 22234-2008). Chinese government firstly published this recommended standard in 2008, which is translated from the Japanese version of <labeling of chemicals based on GHS>.

Then Chinese government realized that they need to have a mandatory labeling standard in place to implement GHS. The new standard is GB 15258-2009, which has added more features that work better for Chinese companies, for example:

- samples of chemical labels(do not exist in GB/T 22234-2008 ) are given.
- black frame of pictogram is acceptable;
- simplified label is available;

A sample of Chinese GHS label can be found below:

Safety Data Sheet Standards

The most important national standard related to Safety Data Sheet (SDS) in China is "Safety data sheet for chemical products: Content and order of sections" ( GB/T 16483 -2008). This recommended standard was published in June 2008 and entered into force in February 2009. It specifies the structure, content and format of Safety Data Sheet in line with China GHS.

The format and content of a Chinese SDS is almost the same as REACH SDS. It is also similar to the 16-headings ANSI MSDS in US. Unless classification changes, simply translating your GHS SDS into Chinese will meet the requirements of this standard. If you have a GHS SDS, we can help you translate it into Chinese at 150 Euros per SDS. We can also help you prepare a new Chinese SDS at the price of 200 Euros per SDS.

Please note that 24h emergency telephone number is required for the SDSs and labels of hazardous chemicals. CIRS works with National Registration Centre of Chemicals(NRCC) to provide this service.

GHS Labelling for Consumer Products in China

Most of the consumer products containing chemicals may be not only subject to main Chinese chemical control laws and GHS requirements, but also subject to relevant product specific national standards and additional labeling requirements(format, content, font size etc). Those consumer products include detergents, cosmetics, paints, lubricants, adhesives, aerosol products, and pesticides for households, etc. Some of those standards are listed as below:

-GB/T 25322-2010 消费品安全标签Safety Label of Consumer Product

- QB/T 2952-2008  洗涤用品标识和包装要求 Requirements for detergent marks and packaging

- GB 5296.3-2008 消费品使用说明 化妆品通用标签 Instruction for use of consumer products-General labeling for cosmetics

- SH 0164-1992  石油产品包装,贮运及交货验收规则 Rules for the Packing, Storage, Transportation and Inspection upon Delivery of Petroleum products (applicable to Lubricants, industrial oils and related products )

- BB/T 0005-2010 气雾剂产品的标示、分类及术语 Labelling, classification and terms of aerosol products 

- GBT 18419-2009  家用卫生杀虫用品 杀虫气雾剂 Domestic sanitary insecticidal-Aerosols

In China, GB 13690-2009 General Rule for Classification and Hazard Communication of Chemicals clearly says that the standard applies to both workplace chemicals and consumer products. However, the current situation is that GHS labeling for consumer products is only being done on a voluntary basis in China. Both GB 15258-2009 and GB 13690-2009 are only technical standards (not laws) giving guidance on how to communicate hazards and label chemical products. There is no specific law in China pointing out that chemicals-related consumer products must be labelled in accordance with GHS standards yet. It is also not clear whether China will adopt risk-based labelling approach for consumer products in accordance with annex V of UN GHS.

However, GHS labelling for consumer products has become a trend as more countries or regions have adopted or recommended GHS labelling for consumer products(for example, EU and Japan).

More info about our label review and preparation services for consumer products can be found here.

China REACH and China GHS

In case of typical notification of new substance in China, Chinese SDS and classification based on above national standards shall be provided.

For more information about the differences between China GHS, UN GHS, and CLP regulation, please click here.

Transportation of Dangerous Goods(TDG)

China's national standards have linked TDG with UN GHS. In Oct 2011, China has released two revised national standards for dangerous goods. Those two standards are consistent with the 16th revised edition of the <UN Recommendations on the Transport of Dangerous Goods>.

Those two standards are available from:

GB 6944-2012, Classification and code of dangerous goods

Gb 12268-2012, List of dangerous goods

Our Services

• Free regulatory advice;
• New! Free chemical inventory search service;
  • IECSC 2010;
  • Catalog of Hazardous Chemicals;
  • Catalog of Highly Toxic Chemicals;
  • Prohibited Chemicals(2005);
  • List of Toxic Chemicals Restricted to Be Imported/Exported

• Preparation of SDS and labels in accordance with China GHS;
• Updating/translating your SDS into Chinese;
• Label review and preparation for consumer products;
• Support to chemical classifications and labeling in China;
• 24h emergency telephone service(working with NRCC);
• Training;

 

Please note: Compared to other translation service providers, our price is very competitive and our knowledge with China GHS and REACH SDS allows us to translate your SDS more professionally using standard phrases.

About Us

Initially set up by China Inspection and Quarantine(CIQ) Bureau in 2007 to provide REACH compliance services to Chinese chemical industry, CIRS has grown to be a leading provider of comprehensive chemical compliance services for companies doing businesses in/with China.

Our services cover new substance notification, registration of the import and export of toxic chemicals, registration of hazardous chemicals, classification and labeling in according to China GHS, Chinese SDS, risk assessment of industrial chemicals, food additives and cosmetic ingredients. We provide one-stop solutions to your regulatory issues in China. We also deliver the most up-to-date regulatory information about chemical control laws in China.

Contact

• Mr. Yunbo Shi, Europe Office
  Singleton House, Laurence Street, Drogheda, Co. Louth, Ireland
  Tel : +353 41 9806 916 | Fax : +353 41 9806 999
  Email: yunbo.shi@cirs-reach.com
• Mr. Eric Xiong, China Office
  11F Building 1, Dongguan Hi-Tech Park, 1288 Chunbo Road, Binjiang District, Hangzhou 310052, China
  Tel: +86-571 8720 6555 | Fax: +86-571 8720 6533
  Email: eric.xiong@cirs-reach.com