Chemical Watch Forum

A Chemical Watcher · November 2011

If I have to label according to GHS and the import country (we exporting to) has GHS not implemented yet, how do I label? We have the GHS labels. The other country has still the old orange symbols. Do I have to change labels at some time on the transport? When? Where? How do other companies manage that?

A Chemical Watcher · November 2011

We have to label our substances according to GHS. Our customers in the Arabic countries still use the orange symbols. How do companies handle the labelling in such a case?

Starting the transport with GHS-label and change labels at sometime …(where, when, who)?

Is there anybody, who can give me advice?

A Chemical Watcher · November 2011

We also face the following problem:

We are forced to label packages according to EU-regulations.
The chemicals are shipped to a country which still has the old regulation and has not yet implemented GHS.
In that case we expect problems regarding the customs release on the one hand, on the other hand the chemicals are stored in a warehouse at the destination seaport and have to be transported from there to the customer’s works.

Before the arrival to his works the customer has no chance to change any labels.

We see 3 alternative approaches:

1) Labeling is done according to EU-regulations - we do not meet the destination country’ regulations

2) Labeling is done according to the destination country’s regulations - we do not meet EU-regulations which might cause trouble because the packages are stored at the European seaport for a couple of days before shipment

3) Therefore, we are wondering if we may put both the labels as per EU-regulations as well as the labels according to destination country’s regulations on the packages. This way we would meet the legal requirements of the EU and the destination country.

We would be grateful if you could support us in answering the question if approach No. 3) would be allowed.

We have contacted numerous experts in the field of dangerous goods, but no one was able to answer this question until today.

Andrea Volpato · December 2011

Dear Sir/Madam,

e.g. an european exporter of chemicals is obliged to label and pack according to CLP without prejudice to any specific requirement of the importing Party, taking into account international standards (european regulations).

As per above I deem chemicals should be labelled and packed according to CLP and GHS and importing party regulation if different from GHS

Andrea Volpato

advisor

Melih Babayigit · February 8

Dear All,

Above mentioned problem is also applicable for EU exports to Turkey. As a Turkish consultant I would like to express that, although there is a project going on about implementation of CLP in Turkey and the draft regulation is under consultation of the stakeholders and there is no official publication up to date.

I assume the best solution would be separating labelling requirements in to two;

1) Transport labelling: As far as you have labelled your products according to ADR or other transport labelling disciplines, you will be in compliance with the regulations as the product is on the transit transport and not placed on the market for the use.

2) Supply labelling: At that point as your products that are shipped to a country where GHS or CLP hasnt been implemented yet, they should be having the labels on in compliance with the target market country regulations as this is where the product will be placed on the market for the users who need the information on the supply labelling.

I assume the above is the best solution instead of a relabelling as far as the products are targeted to a single regulatory area. If there is a potential of region shipments that are to be distributed to CLP and non CLP countries, the problem becomes dramatic and there is no way to resist a relabelling requirement.

I hope the above helps and if there is any point that I'm misinterpreting I would be thankful to hear.

Melih Babayigit / CRAD Turkey

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