To safely handle toxic and concerned chemical substances, the Regulations for the Labeling and Materials Safety Data Sheets for Toxic and Concerned Chemical Substances were revised, adding required minimum sizes for labels on containers and packaging. Another focus is to adjust specifications for the Ministry of Labors (MOL) chemical substance labels, which include disclosure methods for harmful ingredients in toxic and chemical substances, and revise the specific items to be disclosed if certain chemicals do not fall under any risk classifications. The purpose is to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHG), following its regulations on contents required to be put on labels as well as labelling requirements for individual toxic and concerned chemical substances.

Having studied EU and other international regulations, the EPA has revised the specifications for labels on containers and packaging. There are four levels based on volume sizes. Minimum label size is A5 for the top level (the biggest volume) and halved for the next level, and so on. Manufacturers or importers of toxic and concerned chemical substances are to ensure that labels on containers and packaging cannot be smaller than the required size, and should provide clear information concerning risks and dangers for the benefit of users. For specific size-related or other reasons, labels should be presented in a folded form, as hanging tags or displayed on the outer packaging.

Based on the Chinese National Standard (CNS) 15030, a toxic and concerned chemical substance needs to be assigned a risk category, and related information about its risks is to be disclosed on the labels accordingly. If the concentration of such a substance in a product reaches a level required for control, additional information of dangerous ingredients on container and packaging labels as well as bulletin boards are to be disclosed, such as their English name, Chemical Abstract Service number, and the contents weight and concentration. Not only so, either Toxic Chemical Substance or Concerned Chemical Substance is to be shown on the labels. If a toxic and concerned chemical substance is determined as not under any risk category, the revisions state that it is only necessary to put the name, harmful ingredients, warning, other additional information, as well as the names, addresses, and phone numbers of the manufacturer, importer, or supplier.

Moreover, warnings or other supplementary information should be put on labels of toxic and concerned chemical substances according to regulations concerning individual substances. And the EPA will announce what written information or images are to be included on labels based on a substance’s characteristics and management purposes. For example, laughing gas is listed as a concerned chemical substance due to its abuse, so words like for industrial use only; no consumption are to appear on the labels as a warning.

A meeting concerning this revision was held in Aug. 2022. For the entire supply chains of toxic and concerned chemical substances, existing regulations on contents and specifications concerning contents and sizes of container and packaging labels have been revised, and such amendments will take effect on 31 Oct. 2023. A year of grace period will be given to enterprises.

Excerpt from Major Environmental Policies, November 2022