During the COVID-19 pandemic, you may have questions about the rules for importing and manufacturing hand sanitisers.
23 April 2020
This guidance is for industry professionals, who may or may not be experienced in manufacturing hand sanitisers, to point them to their legal obligations.
It is your responsibility as an importer or manufacturer to ensure you are abiding by New Zealand law. This guidance covers specifics under the Hazardous Substances and New Organisms (HSNO) Act 1996.
Our Hazardous Substances Compliance Advisors are working remotely throughout this time, and remain available to help if you cannot find the information that you need in this guide. See our contact details below.
The general rules for all hazardous substances
Before a hazardous substance can be imported or manufactured in New Zealand, it must be:
- approved, either individually or in a group standard (depending on their ingredients, hand sanitisers may be approved under the Cosmetics Products group standard 2017, which contains specific controls (restrictions) for the chemicals in cosmetics, including those in hand sanitising products)
- you must understand your product’s hazardous properties
- your product must be labelled and packaged correctly and have a current safety data sheet (SDS)
- if this is the first time you have imported or manufactured a hazardous substance (and most hand sanitisers are hazardous substances), you must give us your business contact information.
Check the requirements in the Cosmetic Products group standard (pdf 0.5MB) and in Schedules 4-8 (pdf 3.1MB)
Specific rules for hand sanitisers with hazardous properties
- Do not decant hand sanitisers for sale to the public if they contain methanol due to the risk of poisoning through absorption of methanol through the skin, particularly in children, through the overly frequent use that may occur during this COVID-19 pandemic.
- Important: if you are repackaging and/or relabelling any hazardous substance, you are considered a manufacturer.
- If you list the National Poisons Centre on product labels, you must supply the Safety Data Sheet to the National Poisons Centre at email@example.com.
Need more help?
If you haven’t found what you need here, contact us.
Call us on 04 916 2426 or e-mail us at HScompliance@epa.govt.nz
Finding a consultant to help you
Navigating and finding out all of the rules can be time-consuming and tricky – you may wish to hire a consultant to help you. We suggest finding a consultant:
- through the Health and Safety Association of New Zealand (HASANZ)
- by approaching hazardous substance certifiers (see the WorkSafe Website for a list of certifiers) or
- asking for recommendations from colleagues with experience in manufacturing hazardous substances.
Other non-HSNO legal obligations you should be aware of
- Storage, transferral, and use of hazardous substances in a workplace are covered by the Health & Safety at Work (Hazardous Substances) Regulations 2017
- Transport rules apply when hazardous substances are being transported within New Zealand
- Make sure the claims about the effectiveness of your product are accurate
- The New Zealand Customs Service approves the supply and use of duty-free ethyl alcohol for certain purposes
Important: In certain circumstances, hand and skin sanitisers are regulated as medicines under the Medicines Act 1981
- Contact Medsafe for further information: firstname.lastname@example.org
- See also advice from the Ministry of Health on the effectiveness of certain hand sanitisers against COVID-19