Chemical Consumer Products Labelling Review and Preparation for China

Unlike cosmetics, biocides, pesticides and disinfectants, many chemical products for consumer use do not require pre-market registration. However, they may not only be subject to main Chinese chemical control laws and GHS requirements, but also be subject to relevant product specific national standards and additional labeling requirements. GB 13690-2009 specifically mentioned that China's GHS national standards apply to both workplace chemicals and consumer products.

Example of those consumer products include detergents, paints, fuel additives, lubricants, air fresheners, adhesives and aerosol products, etc.

What is New?

26 Oct 2012, CIRS to hold workshop on safety assessment of personal care products and new ingredient in China. Click here for more information.

What does a good label look like?

A good label for chemical consumer products should include at least two parts: GHS elements and non-GHS elements.

GHS elements should meet the requirements of GB 13690-2009 and GB 15258-2009. GHS elements refer to:

  • Product name;
  • Ingredients' info (may be claimed as confidential);
  • Correct GHS classification;
  • Signal word;
  • Hazard pictogram;
  • Hazard statements in standard phrases(not just translations);
  • Precautionary statements in standard phrases;
  • Manufacturer or distributor's Info;
  • 24 emergency telephone number;
  • Correct color;
  • Correct size;


Non-GHS elements include

  • Company logo;
  • Product name;
  • Volume or net weight;
  • Product description;
  • Directions for use;
  • Country of origin;
  • Batch code;
  • Storage conditions;
  • Manufacturing date;
  • Shelf-life;
  • Other elements required by specific product standards(for example, aerosol products).

Our Services

  • Review of Product Category and Ingredients

We review product category and product ingredients and then determine if the product or ingredient requires registration or approval before it is marketed in China. We also check to see if the product contains any restricted or banned substances.

  • Product or Ingredient Registration

We help companies register their product or ingredient if necessary.

  • Classification and Labelling Review

We review the classification and existing labels of a chemical consumer product, and prepare compliant Chinese label in accordance with relevant laws and national standards specific to a product. We also prepare Chinese GHS compliant SDS(if required).

  • Risk Assessment of Consumer Products

We conduct risk assessment on consumer products to determine if a product is safe, based on hazard and exposure information of each ingredient. We also use risk-based approaches to select appropriate hazard statements for consumer products GHS labeling(not compulsory in China).

  • 24h Emergency Telephone Number

A domestic 24h emergency telephone number is required for the precautionary label for chemicals imported into China. CIRS works with NRCC to provide this service. More info can be found here.

About Us

Chemical Inspection and Regulation Service (CIRS) is an independent firm providing comprehensive hazardous substance testing and chemical regulatory consulting services with a strong focus on chemical compliance in EU and China. We are dedicated to providing valued chemical compliance services and solutions by delivering valued information through original expert analysis.

CIRS has helped dozens of companies who manufacture chemicals-related consumer products comply with China's labelling legislation.

Regulatory Support

Please contact us at or find more information on our new website:

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