As the first country to fully implement the Globally Harmonized System on Classification and Labelling (GHS) in July 2006, New Zealand is now facing the challenges of leading instead of following the trend.
GHS is supposed to be a consistent system, however the 3rd revised edition was released in July 2009 and implementing countries follow any edition, or as is the case in New Zealand, the draft version from 2000. This has led to significant differences in the so-called worldwide harmonsiation of chemical classification and labelling.
In early 2009, an Australian industry association applied to the New Zealand chemicals authority – the Environmental Risk Management Authority (ERMA) – to extend from 31 December 2010 until 31 December 2020 a labelling exemption for products to fully comply with New Zealand’s Hazardous Substances and New Organisms (HSNO) system.
This exemption currently allows for labels that are compliant with the relevant labelling requirements in Australia, U.S., Canada or any other approved country so long as the product name; 24-hour emergency phone number; information on the New Zealand importer; supplier or manufacturer; and directions for use are provided.
After extensive public consultation, in October 2009, ERMA expressed its preference not to grant this extension, saying that it did not believe it was the most efficient way of managing the risks posed by hazardous chemical products and that it would go against New Zealand’s reputation as a world leader in GHS implementation. This opinion contradicted the majority of submissions received that emphasized the trade and market restrictions caused by the stricter-than-GHS labelling requirements.
The following month ERMA, called for public submissions on a proposal to update its regulations before the end of 2010 to bring these in line with the 3rd revision of GHS. ERMA is concerned that HSNO will be undermined if the differences continue, and prefers to be more in line with what Australia is expected to implement for GHS, which follows the 3rd revision.
New Zealand might be the first to face these issues, while the majority of the world is still addressing how to implement GHS in the first place, but we can expect other early implementers to also start facing this challenge soon.