1. Mismatch or Omission of Pictograms and Hazards
Using incorrect pictograms, such as mislabeling "corrosive" as "flammable"; Omission of secondary hazard pictograms when there are multiple hazards; Color distortion during printing (e.g., red borders turning gray), failing to meet the GHS standard of red border, white background, and black image.
✅ Typical Case: An exported cleaning agent containing strong acid was deemed a major safety hazard by customs because the label did not use the "corrosive" pictogram.
2. Incorrect or Downgraded Use of Signal Terms
Using "Warning" when "Danger" should be used, artificially lowering the warning level; Simultaneous use of "Danger" and "Warning," causing information confusion; Failure to select a signal term based on the most serious hazard category.
⚠️ Regulatory Basis: GB 15258-2009 clearly stipulates that only one signal term can be selected, and it must be consistent with the hazard description.
3. Inconsistent Labeling and Safety Data Sheet (SDS) Information
The hazard categories, pictograms, or precautions on the label do not match Part 2 of the SDS;
The SDS has been updated to a new classification, but the label still uses the old version; Conflicting content between the Chinese and English labels on exported products.
✅ Customs Case: A company exported hazardous chemicals whose label did not list "acute toxicity," but it did in the SDS. This was deemed non-compliant and the company was ordered to rectify the issue.
4. Inadequate Emergency Contact Number
No 24-hour emergency contact number provided; The provided phone number is not supported by an organization within China (a common problem with imported chemicals); The phone number is invalid or cannot be reached.
⚠️ Mandatory Regulation: Imported hazardous chemicals labels must include a domestic 24-hour emergency contact number.
5. Missing Ingredient Information or Incorrect Concentration Labeling
Mixtures do not list the names and concentration ranges of the main components contributing to the hazard; Commercial codes (e.g., "solvent A") are used instead of chemical names and are not stated in the SDS; Key ingredient information is omitted from small package labels.
✅ Risk Warning: Missing ingredient information may lead to downstream users misjudging reaction risks and causing accidents.
6. Incomplete or Incorrectly Ordered Label Elements
Missing reference warnings, precautionary instructions, or supplier identification; Hazard statements (H statements) not arranged in the order of "Physical → Health → Environmental"; Signal words, pictograms, and hazard statements not grouped together in the same area.
⚠️ Standard Requirements: GB 15258-2009 clearly requires that label elements be complete and arranged in an orderly manner.
7. Label Physical Condition Not Meets Standards
Improper placement (e.g., affixed to the bottom of the container or obscured); Printed on ordinary paper and then affixed, easily detached or blurred; Label edges lack a black border, not meeting GB 15258 requirements.
✅ Practical Recommendation: For highly corrosive substances, it is recommended to use laminated labels or metal nameplates to improve durability.
8. Failure to Update Labels promptly
Using outdated labels from years ago, failing to adapt to the new GB 30000 series standards;
Failure to revise labels promptly after discovering new hazardous characteristics (such as carcinogenicity);
Failure to respond to GHS or EU CLP regulations updates, leading to export disruptions.
⚠️ International Warning: ECHA spot checks in Europe show that 35% of SDS exports to the EU are non-compliant, with 67% lacking information on nanoscale forms.
9. Overly Simplified Labeling for Small Packages
Emergency contact numbers or pictograms are omitted from reagent bottles with a volume ≤100 mL;
Misconception that "small quantities exempt from liability" leads to complete lack of labeling;
Handwritten labels with non-standard information are used.
✅ Correct Practice: While precautionary instructions can be simplified for small packages, core elements must not be omitted.
10. Failure to Relabel After Repackaging
Using the original manufacturer's label after repackaging or transferring to new containers;
Failure to have new labels made and affixed by the changing unit;
Label information lags behind the actual product condition. ⚠️ Regulations clearly state that any entity that repackages chemicals must relabel them.
