Recently, New Zealand's Environmental Protection Authority (EPA) opened a public consultation on amending the Graphic Materials Group Standard 2020 (HSR008053). The proposal would lower the age definition of regulated "children" from the current 12 years and under to 7 years and under, remove low-risk stationery such as pens and pencils from control under the Hazardous Substances and New Organisms (HSNO) Act, and exempt certain products from labelling and Safety Data Sheet (SDS) requirements. Feedback is due by September 29, 2026.
Background of the Proposal
The amendment was jointly proposed by the New Zealand Toy Distributors Association and the Australian Toy Association. The EPA states that the proposal aims to focus regulation on high-risk graphic materials, ease compliance burdens while continuing to manage risks, and align with international regulatory practice.
Key Proposed Amendments
The core amendments include:
- Lowering the regulated children's age: Citing research, the EPA notes that the risks children face from graphic materials decline significantly after about age 8. It therefore proposes lowering the age definition (the applicants originally suggested "under 96 months / approximately 8 years"; the EPA proposes "7 years and under").
- Removing low-risk stationery: Pens, pencils, and other stationery with negligible risk would be excluded from the group standard and no longer subject to HSNO control; such products remain covered by New Zealand's Consumer Guarantees Act and Fair Trading Act.
- Exempting certain labelling and SDS requirements: For products classified as hazardous to human health only because New Zealand adopts lower GHS mixture concentration cut-off values, and which recognized international regulators would not so classify, the EPA proposes exempting them from the Labelling Notice and SDS notification requirements.
- Clarifying scope and limit references: The standard would explicitly also apply to products that "do not trigger a hazard classification but contain one or more hazardous components"; elemental migration limits continue to reference European Standard EN 71-3.
Impact on Enterprises
If adopted, the amendments would relieve some HSNO compliance burdens (e.g., labelling and SDS) for enterprises exporting low-risk stationery and art supplies to New Zealand. However, products that "contain hazardous components but do not meet a hazard classification" would be explicitly brought under the group standard, and relevant enterprises must still comply with its requirements. Overall, regulation will be more focused on high-risk graphic materials aimed at young children.
ChemRadar Insights
Chemical enterprises with relevant business in New Zealand should note the following:
- Verify product scope: Against the proposed age definition (7 years and under) and product use, assess whether your graphic materials still fall under the group standard, particularly products aimed at young children.
- Pay close attention to labelling and SDS exemptions: Check whether your products fall into the category "classified as hazardous only because of New Zealand's lower GHS cut-off values," and assess whether future labelling and SDS exemptions may apply, while still confirming other group-standard obligations for products containing hazardous components.
- Seize the feedback window: If you have views on the age definition, the scope of excluded stationery, or elemental migration limits, you may submit feedback to the EPA by September 29, 2026, via email (GraphicMaterialsAmendment@epa.govt.nz) or the online form.
