Case Description

Company A is a manufacturer of chemical products (non hazardous chemicals), and its products may cause skin irritation, eye irritation, and other hazards. Company A does not know what type of identification and labeling regulations should be followed for the labels of its factory products.

Lawyer Analysis

1. If the products of Company A are sold to end users, it is necessary to determine whether the chemical products produced by Company A fall within the category of "skin irritation" specified in the national mandatory standards (referring to reversible damage to the skin after 4 hours of application of the test substance) in accordance with Chapter 4 of the General Principles for Classification and Hazard Disclosure of Chemicals (GB 13690-2009) Hazardous situations such as "eye irritation" (referring to completely reversible changes in the eye after application of the test material to the surface of the anterior eye within 21 days of application). In such hazardous situations, Company A shall carry out identification and labeling in accordance with the provisions of national mandatory standards such as the General Principles for the Classification and Hazard Disclosure of Chemicals, the Code for the Classification and Labelling of Chemicals - Part 19: Skin Corrosion/Irritation (GB30000.19-2013), and the Code for the Classification and Labelling of Chemicals - Part 20: Serious Eye Damage/Eye Irritation (GB30000.20-2013).

2. "Company A's products are not sold directly to end users, but are sold as raw materials to end users after being produced by the next manufacturer. According to Article 1 of the General Rules for the Classification and Hazard Disclosure of Chemicals," "This Standard is applicable to the labeling of chemical production sites and consumer goods," "the label content of the factory products can meet the agreement between Company A and its buyer.", There is no need to label in accordance with the aforementioned national mandatory standards.

The content requirements for factory labels of products produced by manufacturers may vary depending on their product type, nature, functional use, etc. In order to avoid administrative penalties imposed by competent authorities such as the Market Supervision and Administration Bureau, manufacturers should identify and label their products according to various national standards based on the type, nature, functional use, etc. of their products.