1. China GHS – Background

1.1 GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELLING OF CHEMICALS (GHS)

The original revision of GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELLING OF CHEMICALS (GHS) was published in 2003 by the United Nations. Every two years, GHS will be revised and its tenth Revision was published in 2023. GHS system specifies the classification of hazardous chemicals, and Labels and Safety Data Sheets (SDS) to provide hazardous and toxicological information of chemicals. GHS system aims to safeguard human health and the environment in the production, transportation and use of chemicals. Under the influence of GHS, countries around the world proposed their own GHS regulations. China proposed its GHS based on the UN GHS (Rev.4).

1.2 Main contents of China GHS

China GHS is consistent with UN GHS especially in the hazard classification and labels and SDS. That is to say, China is a country adopted UN GHS by building block approach. GHS is a harmonized standard for chemical classification. Labels and SDS are used to disclose the unified elements of chemical hazards. Therefore, the hazard of chemicals can be transmitted through labels and SDSs.

Enterprises manufacturing and supplying chemicals are required to provide labels and SDS to its downstream users. The following chemicals (substances, their solutions and mixtures) are under GHS system: industrial chemicals, agricultural chemicals and daily chemicals. Chemical waste, tobacco and its products, food, medicines, cosmetics, chemical products which are formed into specific shapes or manufactured to a specific design and do not release hazardous substances materials during its use, are not required to obey GHS requirements. The classification and labeling of intermediate products, pesticides, veterinary drugs, food additives and feed additives which undergo chemical reactions in reactors or during manufacture, shall comply with China GHS, unless otherwise specified.  However, raw materials and intermediates of the above-mentioned products are applicable to China GHS.

2. The Implementation of China GHS

2.1 Objective and significance

China GHS can be used to identify chemical hazards by showing its hazard classification. The existence of labels and SDSs in the manufacture, transportation, storage, operation and use of chemicals can indicate the hazard of chemicals for entities under chemical exposure, and further provide guidance for taking precautions, emergency response and safety treatment. The implementation of China GHS is the basis of for the safety management of chemicals in China. Under the China GHS system, hazard classification and data collection of chemicals can be conducted. Moreover, the report and disclosure of chemical hazard can be established. This measure would rise awareness of public protection and strengthen the protection level. In addition, China GHS implementation can reduce trade costs and improve competitiveness in chemical trade. The GHS implementation can unify the hazard classification, reduce the repeated tests, and lower the harm to animals. 

Figure 2-1 China GHS

See the MANUAL OF GHS IMPLEMENTATION IN CHINA (April of 2013) by the Ministry of Industry and Information Technology of China

2.2 Implementation of regulations and inventories

The Chinese government formulates a series of regulations and supporting national standards for the China GHS implementation. On December 1, 2011, the Regulation on the Safety Management of Hazardous Chemicals (Order No. 591) came into effect. According to the provision of Article 3 of Chapter 1 of the Regulation, hazardous chemical is defined. This Regulation also presents the Inventory of Hazardous Chemicals whose 2015 version is implemented currently. Chemicals listed in this Inventory should be classified based on their hazards. The requirements of SDS and label are specified in the Article 15 of the Regulation. Moreover, the Regulation specifies relevant legal liabilities and penalty to clear responsibilities and strengthen the chemical management.

The Measures for the Administration of Registration of Hazardous Chemicals (Order No. 53), published by the Ministry of Emergency Management of China, was implemented on August 1, 2012. According to the Article 6 of Chapter 2 of the Measures, the registration center is responsible for conducting chemical hazard assessments and identifying the hazards of chemicals. In accordance with the Article 12 of Chapter 3 of the Measures (Order No. 53), hazard classification, label of chemicals are required to be registered. On September 1, 2013, the Measures for the Administration of Physical Hazard Identification and Classification of Chemicals (Order No. 60) published by the State Administration of Work Safety was implemented. Methods for physical hazard identification and chemical classifications were also clarified in this Measures (Order No. 60). All 16 physical hazards in the UN GHS shall be considered in the physical hazard identification under the China GHS.

China also published a series of supporting national standards to provide guidance for chemical classification, labelling, SDS preparation and chemical packaging. Details can be seen in Table 2-1.

Table 2.2-1 National standards relevant to China GHS and their implementation time

The following lists of chemicals also facilitates SDS compilation, including the Catalog of Hazardous Chemicals, the List of Chemicals under Priority Control, List of Toxic Chemicals Restricted to be Imported/Exported in China, and the Catalog of Precursor Chemicals. In 2019, the Occupational exposure limits for hazardous agents in the workplace - Part 1: Chemical hazardous agents (GBZ 2.1-2019) was published, which provides data supports for the compilation of Exposure Controls/Personal Protection in Section 8 of China SDS. 

3. Classification and Information Transmission in China GHS

3.1 Classification

3.1.1 Hazard classification and hazard category

GHS hazard classification is the most important and basic part in China GHS. China GHS involves 16 physical hazards, 10 health hazards and 2 environmental hazards. Details of each hazard classification were shown in Figure 3-1. Different from EU Good Laboratory Practices (GLP), China adopts more weak hazard classification, such as flammable liquids-Category 4, Serious eye damage/eye irritation-Category 2B, Hazardous to the aquatic environment-Acute-Category 2 and 3.

Figure 3-1 Hazard classification and hazard category in China GHS

3.1.2 Classification procedure

Before making the hazard classification, we need to collect data related to chemical hazards through tests or researches, such as flash point, viscosity, pH value and toxicological data. These data need to be reviewed to predict the hazard classification of a chemical. After that, these reviewed data are required to be compared with GHS hazard classification to identify its hazard classification. Alternatives to animal testing shall prevail and test data from humans need to be considered in the data selection. Expert judgments should also be considered. Also, existing data on similar chemicals or chemical mixtures are allowed to be used to identify GHS hazard classification. All these methods can be adopted to avoid repeated tests and reduce the number of animals used, to some extent.

If mixtures have been tested, mixtures can be classified on the integral data. If not, GHS bridging principles (see Figure 3-2) can be used to classify untested mixtures under China GHS. If a mixture itself is in short of data related to health and environmental hazards and the existing data is insufficient to apply the bridging principle, this mixture can be classified based on methods specified in relevant national standards and data of ingredients of this mixture.

Figure 3-2 Bridging Principle

3.2 Information transmission

The hazard information of chemicals is required to be transmitted by a global harmonized way to make people in various countries understand. The transmission and publicity of chemicals’ hazardous information are reflected on SDS and labels. SDS and labels in China GHS are similar to that in UN GHS and some China-oriented standards, which makes it more suitable in China.

3.2.1 Safety data sheet (SDS)

China SDS consists of the following 16 sections in Table 3-1. In Section of hazard statement, GHS classifications and labels shall be compiled. The composition of mixtures should be filled in Section 3. Fire-fighting measures are required to be indicated especially for flammable chemicals. The occupational exposure in China should be specified in Section 8. UN number, UN proper shipping name, transport hazard class(es), and packing group should be provided. Regulatory information of chemicals must be presented in Section 15. Please do not omit Section 16.

Table 3-1 16 Sections in SDS

3.2.2 Labels

According to national standard documents (prefixed with GB), label is a combination of text, pictograms, and signal words used to indicate hazards and precautions of chemicals. Label can be pasted or printed on the outer packaging or container of chemicals. A label may include chemical identification, pictogram, signal word, hazard statement, precautionary statement, emergency telephone number, supplier identification and references. A sample of regular label is given in Figure 3-3. The size of a label depends on the capacity of chemical containers or packages. For packages with capacity equal to or less than 100 mL, a simplified label can be provided as shown in Figure 3-4. The difference between a regular label and a simplified label is that precautionary statements and address of the supplier are omitted in the simplified label.

Figure 3-3 sample of Regular Label

Figure 3-4 Sample of Simplified Label

3.2.3 Application of SDS and Label

In addition to regulations mentioned in 2.2, there are some other decrees or policies that impose requirements on the application of SDS and labels. For example, the General Administration of Quality Supervision, Inspection and Quarantine published Announcement No. 30 to illustrate issues related to the inspection and supervision of the import and export of hazardous chemicals and their packaging. Under the Announcement No. 30, a label and SDS in Chinese should be provided when chemicals are inspected for import and export except for bulk products. Products imported to China should be affixed with labels and SDS in Chinese and the label and SDS must be compliance with the requirements of inspection and supervision.

In 2013, the Ministry of Transport of China published the Provisions on the Administration of Road Transport of Dangerous Goods (Order No. 2) which was implemented on July 1. In accordance with Article 32 of Chapter 4, it is required to provide SDS and labels that are completely consistent with chemicals being shipped. Any violations shall be imposed of penalties.

In 2020, the Ministry of Ecology and Environment of China published the Measures for the Environmental Administration Registration of New Chemical Substances (Order No. 12) and Order No. 7 was repealed at the same time. Under Order No.12, new chemical substances not listed in the Inventory of Existing Chemical Substances in China (IECSC) are required to be registered. Regular registration of new chemicals demands the GHS classification of chemicals. The GHS classification of a chemical can be searched in its SDS or label.

In 2021, Guangdong Province advanced trials of "one company, one chemical product and one QR code". After that, many regions have implemented it successively. In this context, companies are required to print or paste a safety information code on the outer packaging or label of chemicals. Otherwise, products may not be able to leave the factory or warehouse. A safety information code is a QR code that includes chemical identification, SDS, label and other information. A QR code will be generated after the registration of chemical substances. The public, government and downstream users can acquire the information of chemicals including CAS number, registration number, company name, SDS and label by scanning this QR code. With QR code, it is more convenient and efficient to transfer the information of chemicals in the supply chain.

4. Administration of hazardous chemicals

4.1 Definition of hazardous chemicals

Under Order No. 591, hazardous chemicals refer to highly toxic chemicals and other chemicals which are toxic, corrosive, explosive, flammable or are combustion-supporting, and can cause harm to the human health, facilities and the environment.

4.2 Chemicals under China GHS management

4.2.1 Chemicals meet the determinative principle or listed in the Catalog of Hazardous Chemicals

The Catalog of Hazardous Chemicals was published in 2015 (referred to as Catalog (2015)). Its adjustment was published in 2022 and "No.1674 Diesel [Closed cup flashing point below 60℃]" was adjusted to "No.1674 Diesel". Chemicals not listed in the Catalog (2015) do not mean that they do not comply with the determinative principles (referred to as the principles). There are 95 hazard categories in 28 classifications under relevant national standards. 81 hazard categories are adopted as the determinative principles of hazardous chemicals (see Figure 3-1). Chemicals listed in the Catalog (2015) or meet the determinative principle are required to provide labels and SDSs.

4.2.2 Chemicals identified as hazardous chemicals

According to the Measures for the Administration of Identification and Classification of Physical Hazards Chemicals, chemicals identified as hazardous chemicals shall comply with China GHS management. Companies are required to compile SDSs and labels.

4.2.3 Chemicals classified as hazardous under GB30000

If companies have data of chemical hazards, they can compare the existing data with hazard classifications given in GB30000.2-2013~GB30000.29-2013. Chemicals identified with hazard classifications under GB30000.2-2013 ~ GB30000.29-2013 are also required to comply with China GHS requirements.

Inventory Search:

The Catalog of Hazardous Chemicals