Sold to the wrong buyer
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How it happens
A retail product sells well and a workshop orders a case. Or an industrial product gets listed on a consumer marketplace. The label was built for one regime and the order came from the other.
What the workplace customer will ask for
A safety data sheet. That request is the usual way this is discovered, because a consumer product outside hazard communication may not have one prepared to the sixteen-section structure.
And what the consumer regime asks that HazCom does not
Child-resistant packaging, for a prepackaged liquid solvent for paints or similar surface-coating materials at 10 percent or more of the named solvents under 100 SUS. An industrial bottle sold into retail may not have it.
So the exposure runs both ways
Neither regime is a superset of the other. Moving a product between channels is a labeling and sometimes a packaging project rather than a listing decision.
Dual-channel means dual artwork
Which is the honest answer for a product genuinely sold both ways. Two labels, two stock-keeping units, and a rule about which goes where. Trying to satisfy both on one label produces something that satisfies neither.
The sheet is worth having regardless
Even where the consumer exclusion applies, a sixteen-section sheet is the document any commercial buyer will want and it costs nothing to have prepared. It also forces the classification work to be done properly.
Decide the channel before the artwork
Because the artwork is the expensive thing to redo and the channel is the cheap thing to decide. That order is the whole control.
Neither regime is a superset of the other
Which is the fact that makes channel changes risky in both directions. The consumer route can demand child-resistant packaging the industrial route does not, and the workplace route demands a sheet the consumer route may not.