One enterprise, one product, one QR code
For hazardous chemicals in China, their manufacturers and importers in China must register them with the National Registration Centre of Chemicals (NRCC) prior to manufacture or importation. By Bryan Zhou, CIRS
This falls under the Measures for Administration of Hazardous Chemicals Registration (hereinafter referred to as the “SAWS Order 53”), which has been in force since 2012. The latest regulatory update is a QR code system that was introduced in 2021 and will be fully implemented later this year. Following its Chinese title, the system is also referred to in English as “One enterprise, One product, One QR code” and is becoming one of the most popular topics in the global chemical supply chain.
Hazardous Chemical Registration
In general, chemicals listed on the Catalog of Hazardous Chemicals (2015) and those that meet the determinative principle proposed by the guidance of the Catalog of Hazardous Chemicals (2015) must be registered under SAWS Order 53. Both substances and mixtures are subject to registration.
Chinese domestic manufacturers and importers which are handling hazardous chemicals shall register them accordingly. Please note that companies outside of China cannot register those hazardous chemicals as registration holders directly, but can complete the registration through their importers.
The registration requires certain information including Chinese SDS and labels, classifications, physical and chemical properties, uses, company information, relative permission certificates, and safety management information. Different documents are required depending on the different activities, e.g., import or manufacture.
The validity of the registration certificate is three years and has to be renewed three months prior to the certificate’s expiry date.
One enterprise, one product, one QR code
In general, for any hazardous chemical product in China, after the hazardous chemical registration is complete, a QR code could be generated directly from the system. By scanning the QR code, the information including hazardous chemical registration, Chinese SDS and labelling will be accesseible. The authorities would like to use this QR code system to encourage enterprises to comply with hazardous chemical registration and keep all hazard information up to date. The QR code is the identification of hazardous chemical. All kinds of enterprises must not sell, purchase, use or transport dangerous chemicals without this code. This is called “One enterprise, One product, One QR code”.
The QR code should be in the righthand corner of the chemical safety label or somewhere suitable on the label. The QR code location should be kept consistent for the same product and same enterprise.
The QR code must also be provided to the carriers or purchasers. The QR code must be printed, pasted or hung in a conspicuous position during transportation.
There are also certain requirements regarding the size and quality when printing the QR code. In particular, the size of the QR code must be determined according to the size of the chemical safety label. Generally, it shall not be less than the size of the pictogram on the chemical safety label, and the length of the short side shall not be less than 1cm. To make sure the code can work throughout the whole supply chain process, the printed QR code must not be easily deformed or damaged.
Latest implementation status in China
The first pilot project started in 2021 in Guangdong province, which was very successful. Currently, it is a very local requirement in different regions. Based on the local customs and authorities, the implementation requirements are quite different. Provinces including Guangdong, Jiangsu, Fujian, Shandong, Zhejiang, Beijing, Hebei, Sichuan are more involved in this new QR requirement.
Practical Tips from CIRS
- Understand the hazardous chemical definitions in China.
- Analyse and determine your hazardous chemical regulatory obligations in China.
- Prepare a qualified SDS and Label according to China’s GHS standards.
- Process registrations and generate QR codes in advance.
- Communicate within the supply chain.
- Check with the local authorities in China.
CIRS is organising a conference on global chemical legislation on 5 October 2023. The event will take place in London.
