Global GHS SDSs and Labelling

What is GHS

GHS (Globally Harmonized System of Classification and Labeling of Chemicals) is a technical guidance published in 2003 by the United Nations (UN), also referred to as the UN GHS/purple book, which is used to address the classification of chemicals by types of hazard and harmonized hazard communication elements, including labels and safety data sheets. Now the lastest version is the 11th rev. UN GHS. It aims at providing a basis for harmonization of rules and regulations on chemicals at national, regional and worldwide level.

GHS hazard pictograms

GHS hazard pictograms means a graphical composition that may include a symbol plus other graphic elements, such as a border, background pattern or colour that is intended to convey specific information.

GHS pictograms for sectors other than transport are assigned a unique alphanumerical code (a total of 9 from GHS01 to GHS09). The pictogram code is intended to be used for references purposes. It is not part of the pictogram and should not appear on labels or in section 2 of the safety data sheet (SDS).

More details about the GHS hazard pictograms could be found here.

Global GHS Implementation

GHS provides the flexibility to allow countries to adopt the building blocks that they require to meet domestic requirements. There may be differences in categories adopted by different countries. However, the overall information such as label elements (pictograms, signal words, hazard and precautionary statements) are harmonized.

The main areas and countries like Europe Union, US, Japan, Korea, China, Brazil, etc. have continuously implemented GHS. In the other words, almost all the industrial countries in the world have implemented GHS or will implement GHS very soon. Even though it is called a "harmonized system", every country or area still has its own specific requirement, such as language or some differences in regulation details.

Understanding SDS

1. What is an SDS?

SDS stands for Safety Data Sheet. It is a comprehensive document that details a chemical's component information, physical and chemical properties, explosion and flammability hazards, toxicity, and environmental hazards. Additionally, it outlines instructions for safe use, storage conditions, emergency response, and transport regulations. Under the global regulatory frameworks, the SDS serves as one of the primary vehicles for transmitting chemical hazard information across the supply chain.

2. Core Content & Regulatory Requirements

When Must an SDS Be Provided?

An enterprise must proactively provide an SDS under the following conditions:

• Regulatory Listings: The product is explicitly listed in a national inventory of hazardous chemicals (e.g., China's Catalog of Hazardous Chemicals).
• GHS Classification: The product is classified as hazardous according to GHS criteria.
• Supply Chain Communication: Even if the above conditions are not met, an SDS must be passed down the supply chain if an importer requests it, or if industry peers/downstream clients apply stricter classification and labeling standards for the substance.

When Must a SDS Be Updated?

An SDS is a dynamic document and must be updated in the following scenarios:

• As scientific understanding deepens, newly acquired physical, chemical, toxicological, or ecotoxicological data may alter the substance's hazard classification or labeling.
• Many countries and regions implement GHS updates with transition periods. Enterprises must update the hazard description sections before these transition deadlines expire.
• Upon completing registration under the EU REACH regulation, a standard SDS must be expanded into an eSDS (Extended Safety Data Sheet). This involves appending exposure scenarios from the Chemical Safety Report (CSR) as an annex.

In accordance with Article 31(7) of the REACH Regulation, registrants must promptly update the Safety Data Sheet (SDS) or extended SDS (eSDS) to communicate updated information down the supply chain, which includes incorporating the newly assigned registration number. For registered substances manufactured or imported at or above 10 t/a that meet the criteria for hazard classification, an eSDS must be compiled post-registration and communicated to downstream users and importers.

An eSDS contains the standard 16-section SDS framework supplemented by an Annex containing Exposure Scenarios. These scenarios delineate the operational conditions, exposure estimations, and specific Risk Management Measures for all identified uses of the substance. Additionally, the full or redacted registration number must be explicitly stated within the eSDS. For substances exempted from the eSDS requirement, the SDS must explicitly state the regulatory justification for the absence of exposure scenarios.

3. Comparison 

SDS vs. MSDS

The European Union and the International Organization for Standardization (ISO 11014) both adopt the term SDS. But in Australia and many Asian countries, it was historically called an MSDS (Material Safety Data Sheet). Both serve the exact same role in the supply chain with minor content variances. Following the implementation of GHS, major regions including the United States and Canada have officially adopted the term SDS. SDS is now the globally unified terminology.

Classification

GHS hazard building blocks vary by country:

• UN GHS & EU CLP: Adopt 28 hazard classifications.
• China GHS: Adopt 28 hazard classifications, explicitly including newer additions like Aspiration Hazard and Hazardous to the Ozone Layer.
• US OSHA HCS: Adopt 26 hazard classifications. The US does not adopt the Hazardous to the Aquatic Environment or Hazardous to the Ozone Layer classifications. However, US HCS retains three non-GHS hazards from its legacy standards: Simple Asphyxiants, Combustible Dust, and Pyrophoric Gas. If a chemical falls within these three categories, an SDS and label are still mandatory in the US.

Contents

Both China and the EU adopt the United Nations' standard 16-section format. Despite having the same 16 sections, they differ significantly beyond language barriers. Specific formatting and data requirements vary for 24-hour emergency telephone numbers, trade secret (confidential business information) claims, sub-section data requirements, and regional regulatory information.

Labelling Requirements

China's GHS labeling requirements are significantly stricter and contain more specific nuances than the EU CLP or US HCS regulations.

China enforces rigid, specific rules regarding layout sequence, physical placement of elements, emergency contact phone numbers (which must be a domestic 24/7 Chinese number for hazardous chemicals), specific fallback "refer to SDS" phrases, strict label dimensions, and specific color requirements.

Our Services

• SDS/Label Authoring
• EU CLP-REGULATION (EC) No 1272/2008
• China GHS-GB/T 17519-2013&GB/T16483-2008
• Japan GHS- JIS Z 7252:2025/JIS Z 7253:2025
• Korea GHS-MOEL No.2025-50
• Taiwan GHS-CNS 15030
• US GHS- Hazcom 2024
• Canada GHS- WHMIS 2022
• Turkey GHS- SEA No. 31330/ SEA No. 29204
• Brazil GHS- NBR 14725:2023
• Mexico GHS- NMX-R-019-SCFI-2011/NOM -018 -STPS -2015
• Malaysia GHS- CLASS Regulations 2013/ICOP 2019
• Thailand GHS- B.E. 2555
• Indonesia GHS- SNI 9030-1:2021, SNI 9030-2:2021
• Vietnam GHS - Circular No. 32/2017/TT-BCT; Circular No. 01/2026/TT-BCT
• Singapore GHS - SS586: 2022
• Australia GHS - WHS Regulations 2023
• New Zealand GHS - Hazardous Substances (Hazard Classification) Notice 2020 & Hazardous Substances (Safety Data Sheets) Notice 2017 & Hazardous Substances (Labelling) Notice 2017
• GHS of other countries and areas: Russia, South-East Asia, Australia, New Zealand, etc. 

Further Information

Singapore to Implement UN GHS Rev.7

U.S. OSHA Amends Hazard Communication Standard to Align with GHS Rev. 7

What Do You Know About the GHS Hazard Pictograms?

Are You Ready for the Latest Approved GHS Regulation (UA CLP) in Ukraine？

2025 Taiwan GHS Regulation Update - Detailed Version