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If after June 1, 2015, the manufacturer or importer can demonstrate that it exercised reasonable diligence and good faith efforts to obtain hazard classification information from the upstream supplier(s) but for circumstances beyond its control, it has not received the necessary information to develop HCS 2012-compliant labels, it may continue to ship containers downstream provided the containers are HCS 1994-compliant labeled.
Even though a manufacturer or importer may have built up a substantial inventory, over time, containers of hazardous chemicals that were packaged for shipment prior to June 1, 2015 should become less of a labeling burden to manufacturers and importers as inventory is depleted. Therefore, all containers of hazardous chemicals shipped by a manufacturer or importer must be HCS 2012-compliant labeled by June 1, 2017.