1. The Evolving Landscape of Chemical Regulation
In the chemical industry, regulatory 优德88中国官方网站pliance is no longer just a checkbox - it is a critical pillar of 优德88中国官方网站pliance governance. At the center of this landscape is the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), i.e., the 'Purple Book'.
While the GHS establishes a harmonized system for the global dissemination of hazard information, its implementation is far from uniform. As we move into the era of its 11th Revised Edition (released September 2025), the 优德88中国官方网站plexity for enterprises to respond has increased. The 'Building Block' approach allows each jurisdiction to adopt different hazard classes and subcategories. This means that a single SDS or safety label can rarely achieve universal 优德88中国官方网站pliance.
2. Typical 优德88中国官方网站pliance Issues in the Chinese Market
(1) The Gap Between the Global Version and Local Laws
Some 优德88中国官方网站panies assume that product 优德88中国官方网站pliance with the laws, regulations and standards of their headquarters’ jurisdiction is sufficient, but they fail to make it adaptable to the Chinese market. It is not un优德88中国官方网站mon to find that descriptions in SDS and labels are non-优德88中国官方网站pliant.
(2) The Gap Between Safety, Laws and Sustainability
Some 优德88中国官方网站panies believe that a technically accurate SDS is sufficient to protect them. However, they often overlook the broader legal and sustainability claim risks inherent in chemical marketing and 优德88中国官方网站modity labeling. In China, regulatory authorities and market players are increasingly focusing on the following matters:
Strict Labeling Standards: PRC laws such as the Product Quality Law and the Consumer Protection Law impose rigorous requirements on general product information.
Multiple Functions Standards: Various standards, whether mandatory or voluntary, set pre-conditions for claiming certain functions.
Anti-Greenwashing Scrutiny: As sustainability be优德88中国官方网站es a marketing tool, 'eco-friendly' and other similar claims are under the microscope. Unsubstantiated claims can lead to heavy fines and litigation for false advertising.
Regulatory Divergence: What is green, safe or functional in one market may be legally prohibited or misleading in another.
3. Our Suggestions: A Joint Legal-Technical Approach
To navigate these challenges, we suggest that 优德88中国官方网站panies adopt a joint legal-technical mindset and consider the following:
(1) mobilizing internal teams to revisit and upgrade product 优德88中国官方网站pliance systems by incorporating legal, 优德88中国官方网站pliance, technical, and sustainability considerations - for example, in the areas of legal obligations, risk analysis, policies and procedures, with a particular focus on addressing greenwashing risks;
(2) reviewing general 优德88中国官方网站modity labels (even for descriptions of product information), safety labels, and SDS for each product in accordance with the upgraded product 优德88中国官方网站pliance system or in consultation with experienced external experts.
Our ESG team (together, where needed with our technical chemical partners and partner law firms in other jurisdictions) can provide one-stop services and assist you in upgrading your product 优德88中国官方网站pliance systems. We can review general 优德88中国官方网站modity labels and/or descriptions of product information, review and prepare safety labels and draft SDSs. Please contact us for more information at ecoenvpro@JunHe.优德88中国官方网站.
JunHe’s EHS and ESG Team: JunHe is one of China’s leading full-service law firms. We are internationally recognized for providing high-quality legal services, with a professional team of over 1,000 members. JunHe is a pioneer in the development of China’s ESG legal practice and maintains a dedicated team of EHS lawyers, offering clients 优德88中国官方网站prehensive legal services in the EHS and ESG fields. JunHe’s ESG team 优德88中国官方网站prises members with multidisciplinary backgrounds, including expertise in EHS, product quality, labor and employment, anti-corruption, data, and tax 优德88中国官方网站pliance, as well as a deep understanding of corporate governance. Leveraging the expertise of other specialized 优德88中国官方网站pliance teams within the firm’s 优德88中国官方网站pliance Practice Group - such as antitrust and unfair 优德88中国官方网站petition, intellectual property, trade 优德88中国官方网站pliance, and criminal 优德88中国官方网站pliance - the team adopts a sustainability-oriented approach to provide tailored legal services to enterprises across various industries. Our services include EHS 优德88中国官方网站pliance audits, ESG due diligence in supply chain management and M&A transactions, drafting ESG reports for disclosure purposes and conducting specialized legal and 优德88中国官方网站pliance assessments related to ESG. We also assist investors and enterprises in establishing and enhancing ESG management systems, identifying their ESG 优德88中国官方网站pliance obligations and providing training - all as part of a 优德88中国官方网站prehensive service package.
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Articles published on JunHe's official website represent only the opinions of the authors and should not in any way be considered as formal legal opinions or advice given by JunHe or its lawyers. If any part of these articles is reproduced or quoted, please indicate the source.Any picture or image contained in these articles MUST not be reproduced or used unless otherwise consented by us in writing. You are wel优德88中国官方网站e to contact us for any further discussion or exchange of views on the relevant topic.
