EU CLP Regulation | Special Rules on Packaging and Labelling

The REGULATION (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures, commonly known as CLP Regulation, entered into force on 20 January 2009. It aligns existing EU legislation to the United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS).

Main Requirements of CLP Regulation

The CLP Regulation requires that suppliers of chemicals classify, label and package substances and mixtures in accordance with the CLP Regulation. Different deadlines are set for substances and mixtures.

The CLP Regulation also requires that suppliers of a hazardous substance (on its own or mixture) notify the European Chemicals Agency (ECHA) of its classification and labeling within one month of placing the substance on the market for the first time. This is often called C&L notification. Please note that there is no small volume exemption for C&L notification.

Classification

The classification of a substance or mixture reflects the type and severity of the hazards of that substance or mixture. Suppliers need to decide on the classification of a substance or mixture by gathering available data and referring to chemical classification criteria given in CLP regulation. This is often called self-classification.

For example, a liquid with flash point between 23 and 60 Celsius degrees will be classified as Flammable Liquid Category 3. Based on this classification, you can easily find its signal word, pictogram, hazard statement, and precautionary statement (see picture below).

Currently CLP's classification criteria are aligned with UN GHS Rev. 5(5th ATP). Certain building blocks are not adopted such as acute toxicity category 5 and flammable liquids category 4.

Annex VI to CLP - Compulsory Classification List

Annex VI of CLP includes harmonized classification and labelling for thousands of hazardous substances. It is mandatory for the suppliers of the respective substances or mixture to apply harmonized classification and labelling.

A few important notes when using compulsory classifications:

• For certain hazard classes, including acute toxicity and STOT repeated exposure, the classification in the Annex shall be considered as a minimum classification;
• For some entries (indicated by the reference ****), harmonized classification has not included physical hazards due to insufficient data. In this case, the correct classification for physical hazards shall be confirmed by testing;
• Please do read notes (i.e., A, B, H) for each entry which contain conditions for the harmonized classifications to apply;

Compulsory classifications in annex VI are available for from ECHA's classification &labelling inventory (C&L Inventory). C&L Inventory also contains classification and labelling information on notified and registered substances received from manufacturers and importers.

If you search ethanol (CAS 64-17-5), the following screenshot will pop up with harmonized classification for ethanol:

CLP Labelling

CLP label contains standard GHS label elements plus supplementary hazard statements (please refer to special rules on packaging and labelling). The picture below is an example of a CLP label from ECHA's guidance:

CLP regulation has also specified minimum dimensions of labels and pictograms under CLP for packages with different capacities (see picture below).

You can check global size requirements for GHS labels here.

Other CLP labelling requirements include:

• 6 p-statements rule: Not more than six precautionary statements shall appear on the label unless it is necessary;
• Language: shall be prepared in the official language of destination Member States;
• Hiding composition info: A request for the use of an alternative chemical name shall be submitted to ECHA and approved by ECHA;
• Small packages (<=125mL): certain GHS elements can be omitted (see example below);

Annex II to CLP - Special Rules on Packaging and Labelling

Supplemental hazard information which have not yet been included in the GHS but which have been part of the EU system in the past shall also be included in SDSs and on labels. A few examples are given below:

Example 1: Mixtures containing more than 0.15% lead by weight

EUH201- 'Contains lead. Should not be used on surfaces liable to be chewed or sucked by children' shall be labelled.

Example 2: Mixtures not classified as sensitising but containing at least one sensitising substance

EUH208-'Contains (name of sensitising substance). May produce an allergic reaction' shall be labelled.

Example 3: Labelling of plant protection products

EUH401-'To avoid risks to human health and the environment, comply with the instructions for use' shall be labelled.

In addition to that, CLP also requires child-resistant fastenings and tactile warning of danger on packages for certain hazardous chemicals.

Child-resistant fastenings	For chemicals sold to the general public and classified with acute toxicity, categories 1 to 3, STOT- single exposure category 1, STOP- repeated exposure category 1, skin corrosion category 1 or aspiration hazard; For a substance or mixture containing more than 3% methanol or 1% dichloromethane and sold to the general public;
Tactile danger warning	Normally a small raised triangle(see example below); The purpose is to alert the blind and the partially sighted that they are handling a dangerous chemical; Required for chemical sold to the general public and classified for acute toxicity, skin corrosion, germ cell mutagenicity category 2, carcinogenicity category 2, reproductive toxicity category 2, respiratory sensitisation, or Stot, categories 1 and 2, aspiration hazard, or flammable gases, liquids and solids in categories 1 and 2;

C&L Notification

CLP regulation requires that information on substance identity, classification and labelling of a substance should be notified to ECHA within one month since a substance is placed on the EU market for the first time. C&L notification is very easy and it is usually done by manufactures or importers in the EU. There are various options to submit C&L notifications among which online submission may be the easiest. Please be noted that <1t/y non-hazardous substances do not need to be notified.

Safety Data Sheets

CLP classification and labelling info must be included in Safety Data Sheets. However, SDSs are governed by the REACH regulation. The Annex II of REACH has set out detailed requirements on the format and content of SDSs.

REACH SDS follows a 16 section format which is internationally agreed. The SDS must be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market.

• Section 1: Registration number for substances subject to REACH registration must be provided; Email address mandatory;
• Section 8: List applicable DNELs, OELs, and PNEC;
• Section 15: Info on substances subject to authorization and restrictions; Indication of whether a chemical safety assessment has been conducted;
• eSDSs: Registrants and downstream users that are required to prepare a CSR, must place the relevant exposure scenario(s) into an annex to the Safety Data Sheet.

- See more at: http://www.chemsafetypro.com/Topics/EU/CLP_Regulation_EC_No_1272_2008.html

GHS in Australia

Australia will implement GHS for workplace hazardous chemicals (both substances and mixtures) from 1 Jan 2017. Right now, GHS SDSs and labels are not compulsory in Australia. The model Work Health and Safety Regulations (WHS Regulations) issued in 2011 impose a duty on manufacturers and importers of chemicals supplied to a workplace to correctly classify the chemical according to GHS Rev. 3, label hazardous chemicals in workplace and provide safety data sheets.

Classification and Building Blocks

There is no separate guidance on chemical classification in Australia. The new WHS Regulations directly reference UN GHS Rev. 3. The following building blocks are not adopted.

• acute toxicity - Category 5;
• serious eye damage/eye irritation - Category 2B;
• aspiration hazard - Category 2;
• flammable gas - Category 2;
• acute hazard to the aquatic environment - Category 1, 2 or 3;
• chronic hazard to the aquatic environment - Categories 1, 2, 3 or 4, or
• hazardous to the ozone layer.

Safe Work Australia has published a list of chemicals classified in accordance with GHS. The classifications are non-mandatory under the WHS Regulations, and should be used as guidance only.

Download Australia GHS Classification List

Labelling of Workplace Hazardous Chemicals

Australia has adopted standard GHS label elements for workplace hazardous chemicals. The picture below is an example of Australian GHS label given by Safe Work Australia.

Like many other countries, Australia also has its own unique labelling requirements. Such requirements are set by the Code of Practice for Labelling of Workplace Hazardous Chemicals.

• Must include Australian contact details of the manufacturer or importer;
• Max. number of p-statements: 6~10;
• Additional info required if available: the expiry date of the chemical (if applicable), overseas supplier's contact info, emergency contact number, website address and reference to SDSs;
• Size requirement: see picture below;
• Small containers (size not defined):
• • Minimum info required: product identifier, Australian contact info, and hazard pictogram or hazard statements;
  • Must include as much labelling information as possible, particularly significant hazards;
  • "Refer to the Safety Data Sheet" is recommended;

Safety Data Sheets (SDS)

The format and content of Safety Data Sheets (SDS) are set by the Code of Practice for the Preparation of Safety Data Sheets for Hazardous Chemicals. A SDS prepared in accordance with GHS regulations in other countries (for example, the EU CLP Regulation must be checked for compliance with the WHS Regulations and amended if necessary to bring it into compliance.

• Standard 16-section SDSs;
• Emergency phone number: Must include Australian emergency contact information which is available outside of working hours;
• Pictogram size: >1cm x1 cm and <2cm x2 cm;
• Section 15: Indication of whether a hazardous chemical is subject to the control of International conventions and domestic regulations such as NICNAS.

Information Disclosure on Labels and in SDSs

• General Principle: The chemical identity of a hazardous ingredient contributing to the classification of a chemical or a substance with occupational exposure limits must be disclosed;
• Chemical Identity Disclosure: Use of generic name for a hazardous ingredient only accepted in certain cases (moderate hazard category and no occupational exposure limit established);
• Concentration Disclosure: Percentages should be listed in descending order by mass or volume; If the exact concentration of an ingredient is confidential, the concentration of the ingredient can be disclosed using the following range or narrower range: <10%, 10-30%, 30%-60%, >60%;

Read more at http://www.chemsafetypro.com/Topics/Australia/Australia_GHS.html

Related GHS Info &amp; Resources

• GHS in EU/CLP
• GHS in Switzerland
• GHS in USA
• GHS in Canada
• GHS in Turkey
• GHS in Brazil
• GHS in China
• GHS in Korea
• GHS in Japan
• GHS in Taiwan
• GHS in Singapore
• GHS in Indonesia
• GHS in Malaysia
• GHS in Thailand
• GHS in Vietnam
• GHS in Philippines
• GHS in New Zealand
• GHS in Australia
• GHS in Other Countries

Australia NICNAS - National Industrial Chemicals Notification and Assessment Scheme

The National Industrial Chemicals Notification and Assessment Scheme, known as NICNAS, was established in 1990 under the Industrial Chemicals (Notification and Assessment) Act 1989 with the purpose of protecting workers, the public and the environment from the harmful effects of industrial chemicals.

NICNAS assesses industrial chemicals that are new to Australia for their health and environmental effects before they are introduced to Australia. All new industrial chemicals (i.e. those not listed on AICS) must be notified to NICNAS and assessed prior to their import or manufacture in Australia unless they are exempt.

NICNAS also assesses some priority existing chemicals (PECs) that are already in use in Australia. Companies who introduce PECs to Australia shall also apply for the assessment. If you export chemicals to Australia, you shall check if they contain any new substances or PECs first.

Scope of NICNAS

NICNAS excludes articles (such as plastic chairs and photographic film) and radioactive chemicals. Chemicals that are used solely as medicines, pesticides, veterinary chemicals, food or food additives are not regarded as industrial chemicals and are outside the scope of NICNAS. For a mixture (i.e., cosmetic), NICNAS applies to individual substances in it.

Main Requirements of NICNAS

Requirements	Notes
Business Registration	All importers and/or manufacturers of industrial chemicals for commercial purposes shall register themselves with NICNAS;
New Chemical Notification	A new chemical substance must be notified to NICNAS prior to its manufacture or import;
Annual Report	Annual reports need to be submitted for certain exempt or notified new chemical substances;
Assessment of Priority Existing Chemicals (PECs)	A person must not introduce a priority existing chemical unless an assessment certificate has been applied for;

NICNAS Registration of Businesses

All importers and/or manufacturers of industrial chemicals for commercial purposes are required to register with NICNAS regardless of the amount of industrial chemicals imported and/or manufactured in that registration year. The registration year runs from 1 September to 31 August in the following year. Please be noted that this is business registration, not substance or product registration.

Registration involves paying an annual registration fee and a registration charge, which varies according to the value of the chemicals manufactured or imported.

New Chemical Notification under NICNAS and Exemptions

A new chemical substance is an industrial chemical that is not listed on the Australian Inventory of Chemical Substances (AICS), or is a listed chemical substance subject to a condition of use. Only domestic manufacturers and importers can submit new substance notifications to NICNAS.

The following new chemical substances are exempt from notification and assessment:

• Manufactured in Australia in the course of a program of research, development and analysis (advice of introduction needs to be submitted to NICNAS);
• Imported to Australia solely for research, development and analysis with quantity less than <100kg/y (*);
• At ports subject to the control of Customs (max 30 days) *;
• Posing no unreasonable risk and quantity less than <100kg/y (*);
• Non-hazardous and introduced in a cosmetic with a concentration less than 1% (*);
• (*): Annual report is required ;

The picture below shows how to determine if a new chemical substance requires notification under NICNAS.

Types of Approvals for New Chemical Substances

For those new substances which do not qualify for exemptions, you may apply for two different types of approvals: certificates or permits. The table below summarizes different types of certificates or permits you can apply for a new chemical substance.

Commercial Evaluation Permit (CEP)	For test market purpose; Limited to 4 tonnes and 2 years;
Low Volume Permit (LVP)	<100kg/y new chemical; or <1000kg/y new chemical (must meet low hazard criteria);
Controlled Use Permit (CUP)	A low-risk new chemical because its use, handling and disposal are highly controlled; Limited to certain uses(i.e., export-only);
Polymer of Low Concern (PLC) Certificate	For new polymers meeting PLC criteria; No volume limit;
Limited Notification Certificate (LTD)	small-volume chemicals, biopolymers, and low MW synthetic polymers (NAMW <1000 Da)<=1t/y; or site-limited chemicals, biopolymers, and low MW synthetic polymers (NAMW <1000 Da)<=10t/y; or Synthetic polymers with NAMW >1000 Da that do not meet the PLC criteria; Reduced data requirements.
Standard Notification Certificate (STD)	For >=1t/y new chemicals that do not fulfill the requirements of any other categories above;
Early Introduction Permit (EIP)	Allowing notifiers who have submitted PLC, LTD or STD to introduce a new chemical substance before NICNAS assessment is completed; The new chemical must meet certain prescribed criteria; Permit gets expired when a certificate is issued.

Detailed data requirements for new chemical notification can be found here. The picture below given by NICNAS compares the differences between a certificate and a permit.

Self-assessment vs Non-self-assessment

For PLCs or non-hazardous substances (substances of low regulatory concern), a notifier can self-assess them against specified criteria and provide an assessment report which is screened and amended by NICNAS in consultation with the notifier before publication. The self-assessment time frame (28 days) is much shorter than for non-self-assessment category (90 days). Fee is also lower. In this case, annual report is required.

Annual Report

A person who introduces a new industrial chemical in a registration year under circumstances 1 to 8 (see picture 1) must provide a report to NICNAS stating the name of the chemical, its volume and adverse effects found. The report must be provided before or on 28 September of the following year.

Priority Existing Chemicals (PECs)

A PEC is an industrial chemical for which NICNAS requires investigation in detail because of its potential risks to human health or the environment. A person must not introduce a priority existing chemical to Australia unless an assessment certificate has been applied for.

Where a chemical becomes a priority existing chemical, a person may, within 28 days, apply in writing for the assessment of the chemical. Where the chemical has been a priority existing chemical for longer than 28 days, the person may make a late application. If no application is lodged after a chemical is declared a PEC, the NICNAS Director can request an assessment report be started at any time within 12 months.

The Director may also require relevant persons to supply information required for the PEC assessment. Required info includes hazard properties, test reports, volume, uses, info on downstream users and conditions related to manufacture, handling and storage.

From July 2012, NICNAS began assessing around 3,000 priority existing chemicals. In addition to that, NICNAS has drawn up a candidate list of chemicals to consider declaring as PECs. You can find out if an existing chemical substance is a PEC or candidate PEC or not on AICS.

NICNAS Assessment Reports

If a notification is made under a certificate category, an assessment report will be published on NICNAS's website containing a summary of health, safety and environmental matters considered in the assessment and such recommendations as may reasonably be made to ensure safe use of the chemical. These reports can be access here.

Related Regulations and Standards

• Work Health and Safety Regulations (WHS Regulations) and GHS;

AICS - Australian Inventory of Chemical Substances

The Australian Inventory of Chemical Substances (AICS) is a list of industrial chemicals that are available for use in Australia. Some may only be available for specified/conditional use. Currently, around 40,000 industrial chemicals are listed on AICS.

There are two sections: public section and confidential section. Only the public section is available to the public via the link below:

• http://www.nicnas.gov.au/regulation-and-compliance/aics

When you check AICS, it is very important that you also check if there are any conditions or restrictions applicable if your chemical substance is listed. The picture below shows how to search AICS.

To search the confidential section of AICS, you may submit an inquiry to authority by completing Form AICS 5C - Confidential AICS Search.

AICS and NICNAS

The National Industrial Chemicals Notification and Assessment Scheme, known as NICNAS, defines a new chemical substance as an industrial chemical that is not listed on the Australian Inventory of Chemical Substances (AICS), or a listed chemical substance subject to a condition of use. New chemical notification needs to be submitted to NICNAS unless a new chemical substance is exempt.

Where a chemical is on the AICS, but has a condition of use associated with it, if that chemical is to be used within the conditions of use, the chemical remains an existing chemical and NICNAS need not be notified.

AICS and Priority Existing Chemicals (PECs)

You can also check if an existing substance is on the list of Priority Existing Chemicals (PECs) subject to assessment or if the substance is a candidate PEC on AICS. A person must not introduce a priority existing chemical unless an assessment certificate has been applied for under NICNAS.

Related Regulations and Standards

• National Industrial Chemicals Notification and Assessment Schem (NICNAS);
• Work Health and Safety Regulations (WHS Regulations) and GHS;

GHS in the Philippines

Philippines has already implemented GHS in workplace through the "Guidelines for the Implementation of Global Harmonised System (GHS) in Chemical Safety Program in the Workplace" issued in 2014. GHS SDSs and labels are required for hazardous substances and mixtures in workplace from 14 March 2015. The table below summarizes the latest status of GHS in the Philippines and the main requirements on SDSs and labels for hazardous chemicals.

Read more about Philippine GHS.

California Proposition 65 List and Warning

California Proposition 65, also known as the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted in November 1986 to protect California citizens and the State's drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and to inform citizens about exposures to such chemicals.

There are two main requirements:

• No one shall knowingly discharge or release a chemical known to the state to cause cancer or reproductive toxicity to water or land which lead drinking water contamination;
• No one shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning.

California Proposition 65 List and Safe Harbor Levels

California Proposition 65 List is a list of chemicals known to the State of California to cause cancer or reproductive toxicity. There are more than 950 substances on the list. The list is updated annually. To download the latest list, please click the link below:

• http://oehha.ca.gov/prop65/prop65_list/newlist.html

California adopts safe harbor levels (levels of exposure that trigger the warning requirement) for many listed chemicals. Exposures below those levels do not require a warning. For example, lead is on the list. Jewelry is just one of many types of products that may contain lead. Manufacturers and importers of lead-containing jewelry must warn consumers if they will be exposed to lead in jewelry in an amount that exceeds the safe harbor level of 0.5 micrograms per day.

• Download Safe Harbor Levels for Some Listed Chemicals

The picture below is a sample of California Proposition 65 warning label.

How to determine if a Proposition 65 warning is required for a product?

California Proposition 65 applies only to exposures to listed chemicals. It does not ban or restrict the use of any given chemical by setting a concentration limit for the chemical in a product. The concentration of a listed chemical in a product is just one factor to be considered when calculating its exposure level. The exposure level will be compared with safe harbor level to determine if a warning is needed.

Is a product safe if it carries a Proposition 65 warning?

The purpose of Proposition 65 is to notify consumers that they are being exposed to chemicals that are known to cause cancer and/or reproductive toxicity. Consumers can decide on their own if they want to purchase or use the product. A Proposition 65 warning does not necessarily mean a product is in violation of any product-safety standards or requirements.

Related Regulations and Standards

• Toxic Substance Control Act (TSCA);
• OSHA Hazard Communication Standard;

Source:  Intro to California Proposition 65 by ChemSafetyPro.COM

TSCA for Dummies

The Toxic Substance Control Act is the most important chemical control law in the United States. It has given Environmental Protection Administration (EPA) various authorities to take certain regulatory actions against both new and existing chemical substances.

Pre-manufacture Notice (PMN) for New Substances

Section 5 of TSCA requires anyone who plans to manufacture or import a new chemical substance to obtain EPA's approval by submitting a pre-manufacture notice (PMN) at least 90 days prior to the manufacture or import. A new substance is defined as one substance that is not listed in TSCA Inventory of Chemical Substances.

Applicant must submit completed PMN to EPA electronically with available data and wait for EPA's 90 day review. Toxicology data is not mandatory, but must be submitted if available.

The possible outcomes of EPA's PMN review include:

• Drop or approval: no further regulatory actions (about 90% of PMNs belong to this case);
• Withdrawal;
• Request additional data;
• Approval with some type of restrictions (Consent orders);
• Approval with Significant New Use Rules (SNURs) establishing some type of restrictions. The restrictions apply to both the submitter and other manufacturers and importers of the same substance.

PMN Exclusions and Exemptions

The following substances are excluded or fully exempt from PMN reporting:

• naturally-occurring materials;
• products of incidental reactions;
• products of end-use reactions;
• mixtures (but not mixture components);
• impurities or byproducts;
• substances manufactured solely for export;
• non-isolated intermediates;
• substances formed during the manufacture of an article.

There are other types of PMN exemptions while some exemptions require EPA's approval (i.e., LVE, LoREX and TME). The table below summarizes the special types of PMN exemptions.

PMN and Notice of Commencement (NOC)

When a PMN is approved, a 'Notice of Commencement' (NOC) is required to be submitted to EPA within 30 days of first importation or production. Following receipt of this NOC, the subject chemical substance will be added to EPA's TSCA Inventory of existing chemical substances for the purposes of future importation and/or domestic production.

It shall be noted that substances that benefit from PMN exemptions do not require NOC and will not be added onto TSCA inventory. However, TSCA certification is stilled required for importing those chemical substances to the United States.

TSCA Section 5 (e) Consent Orders

Consent Orders are PMN approvals with restrictions. For example, the orders may require the PMN submitter to take certain risk management measures to minimize exposure and risks. A chemical substance must be in compliance with the provisions of the consent order before it can be manufactured or imported. TSCA section 5(e) Consent Orders are only binding on the original PMN submitter.

Significant New Use Rules (SNURs)

Section 5 of TSCA authorizes EPA to designate use of a chemical substance as a 'significant new use', and require the submission of information to EPA prior to the chemical substance being manufactured (including imported) or processed for that use. Unlike consent order which is only binding on the PMN submitter, SNURs apply to all manufactures and importers of the same substance.

Substances that are subject to SNUR requirements are designated as such by an 'S' flag in the TSCA Inventory. If your chemical substance is subject to a SNUR and your intended manufacture, processing, or use of the substance is a significant new use, you would be required to submit a Significant New Use Notice (SNUN) 90 days prior to the manufacture of that substance.

SNUNs are reported using the standard PMN form and are subject to a 90-day review process similar to that for a PMN. When submitting a SNUN, the submitter should include a cover letter that provides the CFR citation of the SNUR and identifies the specific significant new use(s) for which the SNUN is being submitted.

Chemical Data Reporting (CDR)

The Chemical Data Reporting (CDR) Rules, previous known as Inventory Updating Reporting (IUR) Rules, require manufacturers and importers to report if, for any calendar year since 2011, a chemical substance was manufactured (including imported) at a site in production volumes of 25,000 lbs. CDR is conducted every 5 years. The submission period for the next CDR will begin on June 1, 2016.

TSCA Certification for Imported Substances

TSCA section 13 requires that importers 'certify' their imported chemical substances or mixtures are either: (1) in compliance with TSCA Sections 5, 6 and 7 at the time of import; or (2) not subject to TSCA. Customs can refuse entry of any shipment that does not have a TSCA certification. This certificate could be a self-declaration.

Source: TSCA for dummies by ChemSafetyPro.COM

TSCA Chemical Substance Inventory

TSCA Inventory of Chemical Substances is a list of existing chemical substances that are manufactured or processed in the United States. Currently, there are more than 84,000 chemical substances on the Inventory.

There are two sections in TSCA inventory: public section and confidential section. Only the public portion is available for search. There are two options to access TSCA inventory:

• Option 1: Download the latest TSCA inventory in .CSV file;
• Option 2: Search TSCA inventory online by using EPA's Substance Registry Services(as shown in the picture below).

What does TSCA inventory mean to you?

A substance that is not listed on TSCA inventory will be subject to TSCA section 5 Pre-manufacture Notice (PMN) requirements.

In addition to that, you shall check if your substance is subject to Significant New Use Rules (SNURs) requirements under TSCA. Substances that are subject to SNUR requirements are designated as such by an "S" flag in the Inventory listing. If your chemical substance is subject to a SNUR and your intended manufacture, processing, or use of the substance is a significant new use, you would be required to submit a Significant New Use Notice (SNUN) 90 days prior to the manufacture of that substance. You can also search substances subject to SNURs by using EPA's Substance Registration Services (SRS).

How can I check the confidential portion of TSCA Inventory?

If you cannot find one substance in non-confidential TSCA Inventory data, you may obtain a written determination EPA from by submitting a Bona Fide Intent to Manufacture or Import Notice. However, you need to demonstrate a "genuine intent to manufacture or import."

Are you importing chemical substances to the United States?

TSCA section 13 requires that importers certify their imported chemical substances or mixtures are either: (1) in compliance with TSCA Sections 5, 6 and 7 at the time of import; or (2) not subject to TSCA. Customs can refuse entry of any shipment that does not have a TSCA certification. This certificate could be a self-declaration.

GHS Implementation in the United States

The United States has implemented GHS in workplace through revised Hazard Communication Standard (HCS) issued by the Occupational Safety and Health Administration (OSHA) in 2012. All hazardous substances and mixtures need to be classified and labelled in accordance with the new HCS from 1 June 2015.

Classification & Building Blocks - HCS

• Based on GHS Rev. 3;
• Acute Toxicity 5 not adopted;
• Extra classification criteria for OSHA defined hazards - Hazards Not Otherwise Classified (HNOC): pyrophoric gases, simple asphyxiants, and combustible dust;
• International Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) classifications are mandatory in SDSs;

Read more about labelling and SDS requirements in the US(US GHS).

Related Regulations and Standards

• Toxic Substance Control Act (TSCA);
• California Proposition 65;

New Zealand and GHS

New Zealand is one of the earliest countries that have adopted GHS. New Zealand had adopted a GHS based hazard classification framework in 2001 and had been working on an implementation program since that time. Since July 2006, all hazardous substances had been covered by this GHS-based legislative framework. The table below summarizes the latest status of GHS in New Zealand and the main requirements on SDSs and labels for hazardous chemicals. 

- See more at: http://www.chemsafetypro.com/Topics/NZ/GHS_in_New_Zealand_SDS_label.html