Assign your product to a group standard

Once you know which group standard is relevant to you, the next step is to apply for your hazardous substance to be assigned to it. Find out how.

Find below a brief overview of how to assign a product to a group standard. More in-depth information can be found in the related content. Assigning a product to a group standard can be very technical, so please don't be afraid to ask us for help.

Before you start, you will need to know either the hazard classification of your product. This can be found on the safety data sheet (SDS) or the exact concentration of all components of your product.

Step 1: Is your product exempt or excluded from the HSNO Act? Plus

Some products do not need an approval from the HSNO Act. These include non-hazardous substances, substances for use in an exempt laboratory, radioactive and infectious materials, foods (but not food additives) and ready-to-use human medicines. If your product fits these requirements you do not need to find a HSNO Approval. You may wish to double check to make sure your product is non-hazardous.

Step 2: Is your substance a single component chemical or formulated product? Plus

If your substance is a single component chemical you may wish to look at step 7 before proceeding further (unless your substance is a pharmaceutical, pesticide or veterinary medicine active ingredient).

If your substance is a formulated product you may proceed through the other steps.

Step 3: Does a category of group standard exist for the use of the product? Plus

If your substance is a formulated product, your next step is to check whether there is a category of group standard under which it may possibly fit. To do this, you must check that the intended ‘use’ of the product fits with that allowed under the group standard. The names of the group standards give some indication but there is more information within the scope of the group standards. Note that if you intend to use the product for biocidal purposes (killing something) then it will not fit under a group standard. Not all group standards specify a use, some specify a property of the product, such as class 4 substances.

Broadly speaking, most hazardous substances will fit in a group standard, unless any of the following apply:

  • If you intend to use the product for biocidal purposes (killing something). These include pesticides (herbicides, insecticides, fungicides etc), vertebrate toxic agents, fumigants, antifouling paints and timber treatments.
  • If the substance is a fuel. These include petrol and LPG.
  • If the substance is high hazard it will not fit in a group standard.
  • If the substance has an individual approval, these are commonly single chemicals.

If your substance falls within one of these categories, you may need to check whether there is an individual approval that is a better fit.

Step 4: Classifying your product for its HSNO hazardous properties Plus

You can chose to self-classify your product, or ask for help to do this from either a consultant or someone at the EPA. To classify your product, you will require information on the hazards. It could be either from hazard data (such as toxicity data) on the product or the components, or information from the SDS or either the product or the components of the product. If you find that the product does not trigger any hazard classifications, it does not need to be regulated under the HSNO Act and you can stop.

Caution: The classification of a product is a very technical process, and you should ensure you fully understand what is involved before you decide to self-classify. We have resources that can step you through this (found in the related content links), but if you are at all uncertain, we strongly advise that you seek independent technical advice, or contact us.

 Our database, the CCID, may provide useful information. Learn more about it here.

Step 5: Does the product fit the scope of a group standard? Plus

For your product to be assigned a group standard approval, it must meet the scope of the group standard. You will need to know the intended use of the product (step 3) and the hazards of the product (step 4).

The hazard classification of the product must fit with the classifications set out in the scope of the group standard. Certain hazard classifications of a group standard will be mandatory (that is, for a product to be assigned to the group standard, it must have those hazards), whereas other hazard classifications will be optional.

If there is no appropriate group standard available for your product or the hazard classification, you may be able to assign your product to an existing individual approval. If no existing approval for your product exists, you will need to make an application to the EPA.

Step 6: Does the product contain a CMR toxicant? Plus

Some group standards place restrictions on products containing components that are carcinogenic, mutagenic or reproductive (CMR) toxicants.

If your product has any one or more of the following hazard classifications, you must check that every component that gives rise to those classifications is listed on the New Zealand Inventory of Chemicals (NZIoC):

  • 6.6A, 6.6B (mutagenic component is present in the product)
  • 6.7A, 6.7B (carcinogenic component is present in the product)
  • 6.8A, 6.8B, 6.8C (a reproductive or developmental toxicant is present in the product).

If the component is not listed on the NZIoC, then, generally, the product cannot be assigned to the group standard. An exception to this is when an existing product approved under the group standard is being reformulated, and a CMR component is being replaced with another CMR of a lower hazard classification. In this situation, contact us for further advice.

Step 7: Does the product contain a component not on the NZIoC? Plus

Any product that is imported into, or manufactured in, New Zealand for the first time must be checked to see whether it contains a chemical that is not listed on the NZIoC. A chemical not listed on the inventory is considered to be a chemical that is ‘new’ to New Zealand. Looking up using the Chemical Abstract Service (CAS) number is advisable.

Single chemical

No single component chemical can be assigned to a group standard approval unless that chemical is on the NZIoC. If your substance is a single component chemical, you must check to see that it is listed for use as a chemical in its own right on the NZIoC. If your chemical is listed on the NZIoC for use as a chemical in its own right you can use a group standard approval. If your chemical is not on the NZIoC, or is listed but for use as a component in a substance approved under a group standard only, you must contact us for further advice.

Mixture

If the product does not contain a ‘new’ chemical, then it can be assigned to the group standard. A record of that assignment must be kept.

If your product contains a ‘new’ chemical, then, you must notify us before you can assign it to the group standard, using the notification form.

Application for Notification of New Chemical Components approved under Group Standards (docx 579KB)

Once we've been notified, the product can be assigned to the group standard and it becomes a HSNO approved substance under that group standard. You do not need to wait for the EPA to respond to you

Most, but not all, group standards contain this notification requirement for new chemicals. See the group standard to find out if it contains the notification condition.

More information on the NZIoC

Search the NZIoC

Step 8: Keeping a record of the self-classification and group standard assignment Plus

Once a product has been assigned to a group standard, you must keep a record of the self-classification and assignment and it must be available for inspection at the request of a HSNO enforcement officer. The record must contain sufficient information to allow for third party verification of the product classification and group standard assignment.

Once the importer or manufacturer has assigned a product to a group standard and completed the record, there is no need to notify the EPA. A copy of the record does not need to be provided to the EPA.