New Zealand HSNO Act Compliance

Introduction to the HSNO Act

The management of hazardous substances within New Zealand is governed by the Hazardous Substances and New Organisms Act 1996 (HSNO Act). Administered by the Environmental Protection Authority (EPA), this legislation ensures that hazardous chemicals are imported, manufactured, stored, transported, and disposed of safely. A significant regulatory reform in December 2017 shifted workplace hazardous substances management to the Health and Safety at Work Act 2015, allowing the HSNO Act to focus primarily on environmental protection and public safety aspects.

The EPA is responsible for evaluating and approving hazardous substances for use within the country, while the Ministry for the Environment (MfE) provides overarching environmental policy direction. Proregulations offers expert support to help companies navigate these requirements and maintain full compliance with New Zealand's environmental safety standards.

Entities Subject to the HSNO Act

Any company involved in the handling of hazardous substances within New Zealand must adhere to HSNO requirements. This includes:

• Importers bringing hazardous chemicals or chemical-containing products into New Zealand.
• Manufacturers producing hazardous chemicals domestically.

Compliance ensures that substances entering the New Zealand market are correctly identified and managed throughout their lifecycle to minimize risks to the environment and the public.

Scope and Classification of Hazardous Substances

The HSNO Act applies to a wide range of hazardous substances, mixtures, and products. These are classified based on their hazardous properties:

• Explosive substances, including fireworks.
• Flammable, oxidizing, and corrosive substances.
• Toxic substances, including those with acute or chronic toxicity to humans.
• Ecotoxic substances harmful to the environment.
• Reactive substances that trigger hazardous reactions upon contact with air or water.

The act does not apply to certain categories such as radioactive substances (unless they also possess other hazardous properties), medicines regulated under pharmaceutical laws, food products, and non-hazardous substances.

Compliance and Approval Processes

Before importing, manufacturing, or using hazardous chemicals, relevant companies must obtain an HSNO approval and a corresponding approval code. New Zealand follows GHS-based classification standards under the HSNO Act.

Product Approval Types

There are two main types of approvals:

• Single Standard Approvals: For individual substances or products with unique hazard profiles.
• Group Standard Approvals: For products that share similar hazards and uses.

New Substance Notification

If a chemical contains a hazardous ingredient not listed in the New Zealand Inventory of Chemicals (NZIoC), companies must notify the EPA before the first import or manufacture. The EPA typically reviews these notifications within 15 working days. Once approved, the substance is added to the NZIoC, which is the national inventory tracking hazardous and non-hazardous substances introduced to the country since June 30, 2006.

Proregulations' HSNO Compliance Support Services

Navigating New Zealand's hazardous substance regulations requires detailed hazard assessments and accurate classifications. We provide comprehensive solutions to streamline your market entry.

• New substance notification assistance
  We manage submissions for chemicals not currently listed in the NZIoC to ensure timely approvals.
• Approval code matching and database searches
  Our team helps identify the correct approval category for your product by searching the EPA database.
• SDS and label preparation
  We ensure your Safety Data Sheets and labels comply with New Zealand's specific GHS labeling standards.
• New approval applications
  For products that do not match existing group standards, we handle the full application process, including hazard assessments and regulatory reviews.
• Testing strategy and oversight
  Proregulations develops testing plans and coordinates laboratory evaluations to satisfy data requirements for unapproved substances.

If you need to ensure your hazardous substances are fully compliant with New Zealand's HSNO Act and EPA standards, please contact us.