What is China GHS

China GHS, the Chinese localized “Globally Harmonized System of classification and labelling of chemicals” has been implemented across China since 2008 by adopting the 2nd revision of the UN GHS, with the aim of fulfilling China’s international commitment to implement GHS, made on Sep 4th 2002 during the Johannesburg Conference. Apart from providing better protection against chemical hazards for Chinese citizens, the system is also considered the technical basis for establishing environmentally sound management of chemicals in China. 

To achieve effective cooperation between the relevant enforcing authorities, China developed the inter-ministry conference system for GHS implementation, which involved 12 national departments including the Ministry of Environmental Protection (MEP), the Ministry of Transport (MOT), the Ministry of Agriculture (MOA), the National Development Reform Commission (NDRC) and the General Administration of Customs (GAC), etc. China’s Ministry of Industry and Information Technology (MIIT) is the chief administrator for these interations. Besides, the State Administration of Work Safety (SAWS), the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) and the Standardization Administration of China (SAC) are also actively engaged in the formulation of relevant China GHS standards.

China GHS Standard System

Fig. 1 - China GHS Standard System

Consisting of three parts – classification, labelling and SDS, China’s GHS criteria have been enacted since June 2006 with specific grace periods lasting until 2011. In 2008, 26 classification standards entered into force based on the 26 GHS chemical hazards of UN GHS 2nd revision. More national standards (including the compulsory GBs and the recommended GB/Ts) were enacted in the following years to customize the UN GHS criteria for different usage scenarios in China, with all of their technical content cross-referenced.. Recently, China has updated a batch of essential GHS-related national standards (GB and GB/T) in accordance with the 4th revision of UN GHS and scheduled to put them in force in 2014. The major effective standards are shown in Fig,1.

At present the system is designed exclusively for existing hazardous chemicals in mainland China. The definition of  "hazardous chemicals" is given in the State Council Decree 591, the supreme legislation on hazardous chemicals management and the primary legal base of China GHS enforcement. In practice, Decree 591 demands people to refer to the national "Catalogue of Hazardous Chemicals" (currently undergoing revision, please click to read more) to determine whether a chemical substance falls under the group, thus requiring China GHS compliance. 

Classification

Details of the China GHS classification criteria can be referred to the national compulsory standards, GB 13690-2009, General rules for China GHS classification and hazard communication and 28 GBs (GB 30000.2-2013 ~ GB 30000.29-2013) on the classification, precautionary labelling and precautionary statements for specific chemical hazards. 

In Notice No. 20 and 21 (2013) of Standardization Administration of China, 28 new compulsory national standards was scheduled to take effect as of Nov 1st, 2014 and replace the former 26 standards(GB 20576 ~ GB 20602). Compared with the old standards, the GB 30000 series incorporates two more categories namely "aspiration hazard" and "hazardous to the ozone layer". Actually, all the hazard classes and categories in the 4th revised edition of UN GHS will be adopted by China.

The following tables show the “building blocks” adopted by China. 

Physical hazard

Health hazard

Environmental hazard

Guidance for the Implementation of China 2015 Inventory of Hazardous Chemicals (Trial)

In addition, in the Guidance for the Implementation of China Inventory of Hazardous Chemicals (Trial) published on Aug 19, 2015 by SAWS, official classification results are provided for all the chemicals listed in the Inventory of Hazardous Chemicals (2015). While following these classification results are generally taken as a mandatory requirement, the "lowest classification" and "incomplete classification" principles allow the industry to make their own decisions to a certain extent.

· Lowest Classification: only the lowest applicable hazard classification results are specified for the listed chemicals; Companies can assign higher sub-categories under the same hazard category based on the available and reliable data.

· Incomplete Classification: The guidance does not include the complete hazard categories of the chemicals; companies should supplement other hazard categories by consulting the data of their own, without changing the hazard categories listed in the guidance.

In case there is any disagreement with the official classification and which is not applicale to the principles stated above, companies can submit their opinions and source data to NRCC for expert review.

Labelling

What’s new? A draft GB/T standard on China GHS hazard statements has been published on 10 July 2013 for public consultation. The upcoming new standard will be used as an important technical reference for the implementation of China GHS labelling and SDS standards. Slight modifications in the wording of H and P - phrases have been introduced. (See Chemlinked news)

Labeling is one of the foremost GHS hazard communication elements. A GHS label presents essential hazard data of a chemical product with the following major components:

· Product identifier

· Signal words

· Pictograms

· Hazard statements (H-phrases)

· Precautionary statements (P-phrases)

· Supplier identification

The GHS label is usually affixed/attached to the immediate container of a hazardous chemical product or printed on the outer packing of the product.

The primary China GHS label standard, GB 15258-2009, which has been implemented since 1 May 2010, illustrates essential label elements in a precautionary label (including the precedence of pictograms and hazard information) and other important issues relating to the content, color, size, format, printing, placing and use of the label. Compared to the UN version the China GHS labelling system has a distinct feature of requiring the provision of a 24-hour emergency telephone number. The emergency telephone must be a Chinese domestic land-line (rather than cell phone) with professional support available 24 /7.

Before GB 15258, China published in 2008 a recommended national standard for chemical labelling rules based on GHS, GB/T 22234, by translating the Japanese JIS Z 7251:2006. GB/T 22234 has hazard classification slightly different from GB 13690 in terms of flammable gases, flammable compressed gases and reproductive toxicity (adverse effects on lactation). A sample China GHS label is shown as below:

Fig. 2 - A sample China GHS label

Fig. 3 - English translation of the sample label

The label has six different sizes depending on the volume of the container or package of the chemical. A simplified label size for chemical vessel ≤0.1 L is designed as below:

Fig. 4 - Chinese of the simplified label

Fig. 5 - English translation of the simplified label

Note: For in-depth understanding of China GHS labelling, please refer to Exporting to China? China GHS Labelling Advice

Workplace labelling

Fig. 6 - A sample workplace label

Like what is being practiced for the UN GHS, the China GHS label system is developing in a way to cover as many exposure scenarios of chemical product as possible, such as workplace labelling, transport labelling and consumer product labelling. In July 2013, the China SAWS has released a draft AQ standard 3047-2013 to regulate the compilation and use of China GHS workplace labels. The workplace label, which is used in the area of HazChem workplaces, has added information requirements on physicochemical properties and personal protective equipment besides what should be displayed on a typical GHS label.

Note: To explore differences between workplace labels and labels attached on the chemical itself, please see Chemlinked news here.

Transport labelling

China requires that the GHS label used during transportation be affixed to the shipping package if the chemicals are listed in GB 12268: The List of Dangerous Goods. The transport packaging and labelling should be in compliance with the “UN Recommendations on the Transport of Dangerous Goods (UNRTDG), Model Regulations”. Either the label for combination packaging or the label for single packaging should be applied, depending on actual transporting demands.

Fig. 7 - A sample label for combination packaging

Fig. 8 - Transport labelling for single packaging

Consumer product labelling

GHS labelling for consumer products has been increasingly adopted in the world’s major chemical economies, such as Japan and the EU. In China, the specific label standard for consumer products containing chemicals has yet to be published. However, the official voice from the Chinese NRCC-SAWS has recently confirmed that China is considering formulating a GHS label standard tailored for consumer products. According to the MIIT issued “GHS Implementation Manual in China” (see Chemlinked e-book 21) in May 2013, the pending standard will emphasize the safety notice, which will be displayed on the consumer product label to indicate the potential risks posed to the product consumers. Additional hazard data such as hazard statements, precautionary and emergency measures plus the hazard class should be placed on the product’s user manual if the label is not large enough to hold all these information due to product size.

Besides the general China GHS criteria on labelling and packaging, some specific chemical consumer products may also need to comply with other relevant product standards and specific labeling codes. These products include but are not limited to detergents, paints, fuel additives, lubricants, air fresheners, adhesives, aerosol products, disinfectants and pesticides for households (labelling for cosmetics are otherwise prescribed). A few examples of these standards are listed as follows:

· GB/T 25322-2010, “Safety Label of Consumer Product”

· QB/T 2952-2008, “Requirements for detergent marks and packaging”

· SH 0164-1992, “Rules for the Packing, Storage, Transportation and Inspection upon Delivery of Petroleum products (applicable to Lubricants, industrial oils and related product)”

· BB/T 0005-2010, “Labelling, classification and terms of aerosol products”

· GBT 18419-2009, “Domestic sanitary insecticidal-Aerosols”

The existing classification and labelling standard GB 13690-2009 is applicable to both workplace (industrial) chemicals and consumer chemicals.

Safety Data Sheet (SDS)

The SDS is an essential hazard communication component, which the suppliers of chemical products use to transfer basic hazardous information, (including information on the transportation, handling, disposal, storage and emergency action) to their downstream recipients, public institutions, service providers and other recipients of the chemicals.

China published its primary SDS standard, GB/T 16483-2008 “Safety data sheet for chemical products – Content and order of sections” in June 2008 and put it into force in February 2009. This recommendatory national standard has replaced GB/T 17519.1-1999 and GB 16483-2000. It sets the structure, content and generic layout of SDS for companies that are obliged to prepare a standard SDS for chemical products sold in China. The format and content of the China GHS SDS is almost identical to the SDS required under the EU CLP, both maintaining 16 headings to keep consistent with the UN GHS, listed as follows:

1. Identification 

2. Hazard identification

3. Composition/information on ingredients

4. First-aid measures

5. Fire-fighting measures

6. Accidental release measures

7. Handling and storage 

8. Exposure controls/personal protection

9. Physical and chemical properties

10. Stability and reativity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information

English version available!

GB/T 17519 - 2013 Guidance on the compilation of safety data sheet for chemical products, China — “K-REACH”

GB/T 17519-2013 "Guidance on the compilation of safety data sheet for chemical products" is the essential supplementary document to implement GB/T 16483-2008. This national standard specifies key points of the 16 sections in SDS, the format and style, language requirements and units of measurement. A completed model SDS is provided in the annex of the standard, as well as some recommended data sources for each section.

 GB/T 17519-2013 has taken effect since 31 Jan 2014. A translation in English is available on Chemlinked for reference only,  which is free to download for our standard or corporate members. 

Minor differences exist among the China GHS, EU CLP and US HCS in sections regarding:

· hazard classification (including other hazards),

· product identification,

· label elements,

· emergency telephone,

· mixture identification,

· control concentration/exposure limits,

· toxicological information (Section 11),

· PBT/vPvB assessment (section 12),

· transport in bulk and IBC code (section 14), and

· Regulatory information and chemical safety assessment (section 15).

To explore the detailed comparison of GHS SDS rules, please read Differences among 3 versions of SDS standards – China/EU/USA

Chemical suppliers exporting products to China are strongly advised to be aware of the following Dos& Don’ts when compiling a China GHS SDS:

· Adopt settled Chinese SDS framework;

· Be familiar with basic knowledge of Chinese SDS rules;

· Ensure consistency and completeness of hazard data in the SDS;

· Timely update the emerging information in your SDS;

· Emergency telephone information in China GHS SDS is compulsory;

· No online translating when preparing SDS in Chinese;

For in-depth understanding of China GHS SDS rules, please read Exporting to China? SDS Preparation Advice.

Administrative legislations relating to China GHS implementation

Ebook 21: Manual of GHS Implementation in China

China has prescribed a number of administrative rules and measures to advance the implementation of GHS in China over the past few years. Most of these regulations specify that China GHS classification, labelling and SDS need to be supplied by HazChem manufacturers, importers & exporters, and transport companies. The most significant of them is the State Council Decree 591, “Regulations on the Control over Safety of Hazardous Chemicals”. This overarching regulation outlines general requirements of hazchem enterprises to fulfill the GHS obligations in China along the supply chain. Other ministerial ordinances underneath include:

·       Regulation on the Road Transport of Dangerous Goods (MOT Order 2 of 2013)

·       Measures on the Environmental Management of New Chemical Substances (MEP Order 7)

·       Specifications on the Inspection and Supervision over Entry-Exit Hazardous Chemicals and their Packages (AQSIQ Announcement 30 of 2012)

·       Measures for the Administration of Hazardous Chemicals Registration (SAWS Order 53)

In Decree 591, penalties for the violation of China GHS compliance are severe. Violating companies can be imposed fines ranging from a minimum of 50,000 CNY to a maximum of 100,000 CNY. Some of the possible misconducts specified in the Regulation are listed below:

· Failing to provide appropriate China GHS label or SDS during the production, importation or operation of HazChem products;

· Providing inconsistent hazard data between the label and the SDS, or between inside package and outer package, or hazard data inconsistent with that specified in the Catalogue of Hazardous Chemicals;

· Failing to update in time GHS classification information on the label, or SDS when new hazardous properties of the chemical product arise.

HazChem importers and exporters are strongly advised to take special notice of the AQSIQ Announcement 30 of 2012, which requires the customs inspection to be conducted on HazChems imported and exported. In particular, China GHS labels and SDSs are checked routinely during the entry-exit inspection.

News

· 9 Sep 2015 Guidance for the Implementation of China 2015 Inventory of Hazardous Chemicals

· 24 Dec 2013 GB/T 17519-2013 Guidance on Compilation of SDS for Chemical Products is Officially Published

· 17 Oct 2013 China to Adopt UN GHS Rev.4 with 28 Compulsory Standards for Classification of Chemicals Approved

· 29 Sep 2013 China to Adopt Revised Standard of SDS Complilation GB/T 17519-2013

· 20 Aug 2012 China Plans on New GHS Standards by 2014

· 3 Jun 2013 MIIT Issues Manual of GHS Implementation in China

· 22 Feb 2013 Globally Harmonised System (GHS) for Hazard Classification and Labelling – Potential Misconceptions and Challenges Ahead

· 16 Jul 2013 Chinese Standard for GHS Chemical Hazard Statements on Public Consultation

· 5 Aug 2013 China GHS Labelling - Draft AQ Standard on Precautionary Labels for Chemicals in Workplace

· 29 Nov 2013 MIIT Held the 1st GHS Implementation Expert Committee Meeting

· 12 Dec 2012 Aspiration Hazard and Hazard to the Ozone Layer to be Incorporated into China GHS

Expert Articles & Ebooks

1. Eric Sun, 18 Sep 2015, "Understanding China 2015 Hazchem Inventory Implementation Guidance – Part 3: Compliance Suggestions", Chemlinked

2. Eric Sun, 11 Sep 2015, "Understanding China 2015 Hazchem Inventory Implementation Guidance – Part 2: Classification", Chemlinked

3. Eric Sun, 11 Sep 2015, "Understanding China 2015 Hazchem Inventory Implementation Guidance – Part 1: Implementation Rules", Chemlinked

4. Rita Qiu, 24 Feb 2011, "China GHS - Background, Updates, GB Standards, Classification, Labelling and SDS", Chemlinked

5. Rita Qiu, 6 Feb 2011, "National Standards in China GHS", Chemlinked

6. Olivia Sun, 20 Apr 2012, "China GHS - Introduction, Updates and Technical Know-How on Classification, SDS, Labeling and Packaging", Chemlinked

7. Julian Zhu, 3 Apr 2013, "An Introduction to GHS Pictograms and Transport Pictograms", Chemlinked

8. Rita Qiu, 2 Aug 2012, "Differences among 4 Versions of GHS Classification- UN/EU/China/USA", Chemlinked

9. Lizzy Liu, 4 Sep 2012, "Differences among 3 Versions of SDS Standards - China/EU/USA", Chemlinked

10. Lizzy Liu, 15 Feb 2012, "Exporting to China? China GHS Labelling Advice", Chemlinked

11. Lizzy Liu, 10 Jan 2012, "China Compliant SDS Preparation", Chemlinked

12. Sunny Wang, 15 Nov 2012, "Transport of Dangerous Goods: Legislative System for TDG in China", Chemlinked

13. Rita Qiu, 23 Jun 2011, Ebook04: Managing China GHS Compliance, Chemlinked  

14. Lizzy Liu & Yvonne Huang, 21 Jun 2013, Ebook21: Manual of GHS Implementation in China, Chemlinked

15. Echo Cao, 2 Apr 2013, "Ebook16: GB 28644.1-2012 Excepted Quantities and Packing Requirements of Dangerous Goods", Chemlinked

16. Echo Cao, 2 Apr 2013, "Ebook17: GB 28644.2-2012 Limited Quantities and Packing Requirements of Dangerous Goods", Chemlinked

17. Yvonne Huang, 2 Apr 2013, "Ebook15: Overview of Asia Pacific GHS Progress 2012 (with substances as the key focus)", Chemlinked

18. Jane Zhou, 3 Apr 2015, "Interpretation of China Inventory of Hazardous Chemicals (2015)", Chemlinked