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Relevant regulations for consumer goods labeling in various countries

Posted Date:2024/1/3 1

While the GHS does not address or harmonize specific risk assessment approaches, the following general principles are followed:

(a) All chemicals should be classified according to the Globally Harmonized System classification criteria. The first step in the process of hazard classification and information communication should always be the classification of the inherent hazards of substances and mixtures according to the standards of the globally harmonized System;

(b) Risk-based labelling can only be applied by the competent authority in the context of consumer products for chronic health hazards of chemicals. All acute health hazards, environmental hazards and physical hazards should be labelled according to inherent hazards. The hazard classification should be used directly for acute health effects, environmental hazards and physical hazard labels. Labelling schemes involving risk assessment should only be used for chronic health hazards such as carcinogenicity, reproductive toxicity, or target organ toxicity based on repeated exposure. Applicable chemicals can only be those to which the average consumer is exposed in limited quantities and for a limited time under the conditions of use of consumer goods;

(c) Possible exposure and risk to consumers, and estimates should be based on conservative, protective assumptions to minimize the possibility of underestimating exposure or risk. Assessments or estimates of exposure should be based on data and/or conservative assumptions. Risk assessment and methods for extrapolating animal data to humans should also allow for greater margin of safety, including the identification of uncertainties.


Implementation status of consumer labeling in various countries


Adoption of GHS in consumer products in the EU

· Adopt GHS for chemical consumer products through CLP regulations;

Products sold to the public may require additional labeling information.

· Sample label for two component adhesives sold to consumers.


Adoption of GHS in consumer products in the United States

· Consumer products have not yet adopted GHS.

Only hazardous chemicals used in the workplace will need to be labeled according to the new U.S. Occupational Safety and Hazard Administration (OSHA) Hazard notification standard.

· Please note that consumer use does not include professional use.


Adoption of GHS in consumer products in Canada

· Consumer products have not yet adopted GHS. (In line with the United States)


Adoption of GHS in Chinese consumer products

In 2018, China issued GB/T 36499 "Guidelines for Risk Assessment of Consumer Products Based on GHS Labels" If consumer products have chronic health hazards, suppliers can use the results of the product's GHS hazard classification to make GHS labels for their products.

Note: A "GHS label" for a consumer product needs to be compiled according to the product's GHS classification only if the consumer product has a chronic health hazard. In practice, many consumer products are still regulated as if they were chemicals. Therefore, it is recommended that enterprises comply with the requirements of territorial regulators.


GHS is used in Japanese consumer products

· Voluntary adoption of GHS labels for consumer products.

In consultation with METI, the Japan Soap and Detergent Association (JSDA) has voluntarily developed a GHS guidance document for the labeling of consumer cleaning products. Risk-based labeling is considered.


Adoption of GHS in consumer products in Australia

· GHS is mainly used for hazardous chemicals in the workplace.

Because the line between workplace chemicals and consumer products is not always clear, regulators have given the industry the option to choose between workplace labels and consumer product labels based on marketing channels and end use.