GHS by Country: Globally Harmonized System Map 2026

Over 70 jurisdictions have adopted the UN Globally Harmonized System of Classification and Labelling of Chemicals — but no two implementations are identical. A chemical labeled correctly under EU CLP can fail customs in the United States, Indonesia, or Saudi Arabia. The differences come from three things: which UN GHS revision a country aligned with, which “building blocks” it adopted, and which local hazard classes it added on top.

This guide is for compliance specialists, EHS managers, and regulatory affairs professionals who need to know — quickly — how a specific country regulates chemical hazards in 2026. It covers 22 jurisdictions across North America, the European Union, Asia-Pacific, Latin America, MENA, and Africa, with the regulation name, governing authority, GHS revision aligned, scope, and current deadlines for each.

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At a glance

• Standard: UN Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS), commonly called the Purple Book
• Maintained by: UN ECOSOC Sub-Committee of Experts on the GHS (UNSCEGHS), Geneva
• Latest edition: UN GHS Revision 11, published September 2025
• Revision cycle: every two years
• Total adopters: 70+ countries and territories, plus the European Union as a regional bloc
• Legal status: UN GHS is a non-binding framework — each country implements it through national legislation
• Hazard classes covered: physical (17), health (10), and environmental (3) — countries pick which to enforce
• Related tools on this site: Label Constructor, ATE Calculator

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Table of Contents

1. How UN GHS becomes national law
2. How to read these country profiles
3. Country profiles
   • North America
   • European Union and UK
   • Asia-Pacific
   • Latin America
   • MENA and Africa
4. Common pitfalls and FAQ
5. How GHS Pictograms tools help

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How UN GHS becomes national law

The UN GHS itself is not law. The Purple Book is a recommendation document published by the United Nations Economic Commission for Europe (UNECE) on behalf of the UN Economic and Social Council (ECOSOC). It defines hazard classification criteria, signal words, pictograms, hazard statements, precautionary statements, and the 16-section Safety Data Sheet format. Member states then transpose those rules into domestic legislation — and that is where uniformity ends.

Three mechanisms drive divergence between countries:

1. Building block selection. UN GHS organizes hazards into three groups (physical, health, environmental) and 30 hazard classes. A country chooses which classes to enforce. The United States, for example, regulates chemicals in the workplace through OSHA — and OSHA has no jurisdiction over environmental hazards. The aquatic toxicity classes that are mandatory in the EU are simply not part of the OSHA Hazard Communication Standard. The same chemical therefore needs an environmental hazard pictogram (GHS09) on its EU label and no environmental pictogram on its US label.

2. Revision lag. UNSCEGHS publishes a new edition of the Purple Book every two years. The latest is Revision 11, released in September 2025. Adopting a new revision requires a country to amend its own legislation, which usually takes 2 to 5 years. As of early 2026, the most widely implemented baseline is Revision 7. Some markets are still on Revision 5 or earlier. A few are moving to Revision 8.

3. Local additions. Countries add hazard classes that the UN does not recognize. The EU has done this most aggressively. CLP introduced new hazard classes for endocrine disruptors and for persistent, mobile, and toxic substances (PMT/vPvM) in 2023 — none of which exist in the UN GHS Purple Book. The United States retains a Combustible Dust class that pre-dates GHS. Several jurisdictions add local language requirements, supplemental statements, or country-specific UFI codes.

The result is what compliance professionals call the building block reality: every market needs to be checked individually. The country profiles below give you the entry points.

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How to read these country profiles

Each country profile in this guide answers six questions. They are the same six questions a regulatory affairs professional asks when entering a new market — and they map directly to what you need to put on a label, write into a Safety Data Sheet, and submit to local authorities.

The six dimensions

1. Regulation name. The legal instrument that gives UN GHS the force of law in that jurisdiction. This is the document number you cite when a customs broker, distributor, or auditor asks for the regulatory basis. Examples: Regulation (EC) No 1272/2008 in the EU, 29 CFR 1910.1200 in the US, GB 30000 series in China.

2. Governing authority. The agency that enforces the regulation, accepts notifications, publishes guidance, and updates classification lists. This is who you contact, and who inspects you. ECHA in the EU, OSHA in the US, NITE in Japan, MEE in China, KOSHA and the Ministry of Environment in South Korea.

3. UN GHS revision aligned. Which edition of the Purple Book the national legislation matches. The mismatch between markets is the single largest compliance pain point. A label that satisfies an EU market on Revision 7 may need rework for an EU market that has just adopted Revision 8 elements.

4. Scope and building blocks. Whether the regulation covers workplace chemicals only, consumer products, transport, or the full range of physical, health, and environmental hazards. This determines which pictograms appear on which labels.

5. Language requirements. The official language(s) the label and SDS must use to be sold in that country. The EU alone requires SDSs in 24 languages depending on the destination market. Canada requires bilingual English and French. Most Asian markets require the local language alongside English.

6. Current deadlines. The next compliance event — an Adaptation to Technical Progress (ATP) phase-in, a transition deadline for new hazard classes, or a recent rule that has just become enforceable. As of May 2026, OSHA HCS 2024 substance compliance arrives on May 19, 2026; mixture compliance on November 19, 2027. The EU’s 2023 hazard classes for endocrine disruptors and PMT/vPvM phase in across four staged dates running from May 2025 to May 2028.

Aligned, adopted, implemented — what these terms mean

These three words appear interchangeably in trade press, but they describe different stages and matter when comparing markets.

• Aligned — the country’s law uses UN GHS criteria as the basis, but does not necessarily require every building block. Most national regulations are described this way.
• Adopted — the country has formally enacted legislation referencing a specific UN GHS revision. Adoption does not always equal full enforcement.
• Implemented — the regulation is in force and being enforced, with deadlines past for substances, mixtures, or both.

A country can be aligned with Revision 7, have adopted parts of Revision 8, and be enforcing Revision 6 in practice — all at the same time. The country profiles below state where each market sits.

UN GHS revisions timeline

The Purple Book has been revised eleven times since the first edition in 2003. The timeline below shows the publication date of each revision and the headline change that drove most national updates. Revisions 7 and 8 are the most widely implemented bases worldwide as of 2026.

Notice that newer revisions are not always more demanding — some, like Rev 6 and Rev 8, were largely consolidation editions. The classes that drive label and SDS rework across markets are concentrated in Revisions 4 (aquatic chronic), 7 (Annex 11 expansions), and 11 (atmospheric system, including global warming potential).

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Country profiles

The 22 jurisdictions below cover all major chemical trading economies and the regional blocs they belong to. Each profile follows the same six-dimension structure introduced above. Use the table to filter by region or by UN GHS revision aligned, then jump to the full profile below.

All (22)North America (2)EU & UK (3)Asia-Pacific (11)Latin America (3)MENA & Africa (3)

Country	Region ↑	Regulation	Authority	Aligned
China	Asia-Pacific	GB 30000.1-2024 + 30000.2-29	MIIT / MEM / MEE / SAMR	Rev 8 / 4
Japan	Asia-Pacific	JIS Z 7252 / JIS Z 7253; ISHL	MHLW / METI / MOE / NITE	Rev 6
South Korea	Asia-Pacific	K-OSHA Notice; K-REACH	MoEL / Ministry of Environment	Rev 7
Indonesia	Asia-Pacific	KEMENAKER Reg 187/1999; Permenperin 23/2013	KEMENAKER / Ministry of Industry	Rev 4
Australia	Asia-Pacific	Model WHS Regulations	Safe Work Australia	Rev 7
New Zealand	Asia-Pacific	HSNO Act / Hazardous Substances Regs	EPA NZ / WorkSafe NZ	Rev 7
Philippines	Asia-Pacific	DAO 2009-08; CCO	DENR / EMB	Rev 4
Thailand	Asia-Pacific	Hazardous Substance Act	DIW / FDA / DOA	Rev 5
Malaysia	Asia-Pacific	CLASS Regulations 2013	DOSH	Rev 3
Vietnam	Asia-Pacific	Decree 113/2017; Law 69/2025/QH15	MoIT	Rev 2
India	Asia-Pacific	MSIHC Rules; Chemicals (Mgmt) Rules (draft)	MoEFCC	Voluntary
European Union	EU & UK	CLP Regulation (EC) 1272/2008	ECHA	Rev 7 + ATPs
United Kingdom	EU & UK	GB CLP	HSE	Rev 7
Switzerland	EU & UK	Chemicals Ordinance (ChemO)	FOPH	Rev 7
Brazil	Latin America	ABNT NBR 14725:2023	ABNT / ANVISA / IBAMA	Rev 7
Mexico	Latin America	NOM-018-STPS-2015	STPS	Rev 5
Argentina / Chile / Peru	Latin America	UN GHS direct adoption	Various	Rev 6-7
GCC Region	MENA & Africa	GSO 2654:2021/2025	GCC Standardization Organization	Rev 10
Türkiye	MENA & Africa	SEA Yönetmeliği; KKDIK	MoEUCC	Rev 7
South Africa	MENA & Africa	OHSA HCS Regulations; SANS 10234	Department of Employment and Labour	Rev 7 (in transition)
United States	North America	OSHA HCS 2024 (29 CFR 1910.1200)	OSHA	Rev 7
Canada	North America	WHMIS 2015 / HPR	Health Canada	Rev 7

Click a country name to jump to its full profile below. Tap a column header to sort.

North America

United States — OSHA HCS 2024

• Regulation: Hazard Communication Standard, 29 CFR 1910.1200 (HCS 2024)
• Authority: Occupational Safety and Health Administration (OSHA), Department of Labor
• UN GHS revision aligned: Revision 7, with selected elements of Revision 8
• Scope: Workplace chemicals only — environmental hazards excluded
• Language: English (Spanish translations widely used as supplemental)
• Current deadlines: Substances — May 19, 2026 (manufacturers, importers, distributors). Workplace updates for substances — November 20, 2026. Mixtures — November 19, 2027. Workplace updates for mixtures — May 19, 2028.

The HCS 2024 update was published on May 20, 2024 and represents the first major OSHA revision since 2012. The previous version was aligned with UN GHS Revision 3, leaving the United States more than a decade behind the EU and most of Asia. The new rule closes most of that gap.

On January 15, 2026, OSHA extended each compliance deadline by four months in response to industry requests for additional guidance time. The original substance deadline of January 19, 2026 was pushed to May 19, 2026. The original mixture deadline of July 19, 2027 was pushed to November 19, 2027. During the transition period, manufacturers may comply with either the 2012 standard, the 2024 standard, or both — until the new tiered deadlines pass.

OSHA jurisdiction is restricted to occupational health and safety. That means aquatic toxicity, ozone layer hazards, and the new atmospheric system class from UN GHS Revision 11 are not part of HCS — they fall under the Environmental Protection Agency (EPA) and the Department of Transportation depending on the context. Practical consequence: a US workplace label for the same chemical will not show GHS09 (environment) even if the EU label requires it.

The HCS retains two US-specific classes that pre-date GHS: Combustible Dust and Pyrophoric Gases. It also keeps the Hazard Not Otherwise Classified (HNOC) category for chemicals that show evidence of harm but don’t fit a UN GHS class. SDS Sections 12 through 15 (ecological, disposal, transport, regulatory) remain non-mandatory under OSHA, though most US manufacturers fill them in for international harmonization.

For full hazard profiles on US-classified substances, see the GHSSymbols.com hazards database.

Canada — WHMIS 2015

• Regulation: Hazardous Products Regulations (HPR) under the Hazardous Products Act
• Authority: Health Canada (federal), with provincial occupational health and safety agencies
• UN GHS revision aligned: Revision 7, harmonized with US OSHA HCS 2024 where possible
• Scope: Workplace chemicals; consumer products covered separately under the Consumer Chemicals and Containers Regulations
• Language: Bilingual English and French — both required on labels and SDSs
• Current deadlines: WHMIS 2015 is in force. Health Canada published amendments in December 2022 to align with HCS 2024; full implementation is rolling.

Canada implements GHS through the Workplace Hazardous Materials Information System, version 2015 — usually called WHMIS 2015. The system replaced the original 1988 WHMIS, which used a different set of pictograms and a unique signal-word vocabulary. WHMIS 2015 follows UN GHS structure but keeps one Canada-specific class: Biohazardous Infectious Materials, which retains the original WHMIS 1988 biohazard symbol rather than the eight UN GHS pictograms.

The bilingual requirement is non-negotiable. Both English and French must appear on the label with equal prominence, and every section of the SDS must be translated. Single-language labels are not accepted at the Canada Border Services Agency. Companies serving both the US and Canadian markets typically maintain trilingual labels (English, French, Spanish) to cover the entire North American block.

Health Canada has stated it will continue tracking US OSHA changes to keep WHMIS substantially aligned with HCS — so when OSHA moved to Revision 7 in 2024, Canada followed.

European Union and UK

European Union — CLP Regulation

• Regulation: Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures (CLP)
• Authority: European Chemicals Agency (ECHA), Helsinki
• UN GHS revision aligned: Revision 7 baseline, augmented through Adaptations to Technical Progress (ATPs)
• Scope: Substances and mixtures placed on the EU market — workplace, industrial, and consumer
• Language: SDS in the official language(s) of every member state of sale (24 languages total)
• Current deadlines: New hazard classes from Delegated Regulation (EU) 2023/707 phase in across four stages — new substances from May 1, 2025, existing substances by November 1, 2026, new mixtures from May 1, 2026, existing mixtures by May 1, 2028.

CLP is the most aggressive UN GHS implementation in the world. The EU does not wait for UN consensus — it adds hazard classes ahead of UNSCEGHS and tightens classification thresholds through ATPs published roughly every two to three years. ATP 22 was the most recent; ATP 23 is in preparation.

In December 2022 the European Commission published Regulation (EU) 2023/707, which introduced four new hazard classes that have no UN GHS equivalent:

• Endocrine disruptors for human health
• Endocrine disruptors for the environment
• Persistent, bioaccumulative, and toxic (PBT) and very persistent, very bioaccumulative (vPvB)
• Persistent, mobile, and toxic (PMT) and very persistent, very mobile (vPvM)

The transition is staged in four phases. Substances placed on the EU market for the first time after May 1, 2025 must comply immediately. Existing substances already in the supply chain have until November 1, 2026. New mixtures must comply from May 1, 2026, and existing mixtures have until May 1, 2028. CLP also adds the EUH supplementary hazard statements (EUH001 through EUH401), plus the new EUH440, EUH441, and EUH450 statements introduced specifically for the PBT/vPvB and PMT/vPvM classes — these are EU-specific and do not appear on labels destined for non-EU markets.

For mixture classification under CLP, including the strict cut-off values for new hazard classes, the ATE Calculator on GHSSymbols.com handles the additivity formula.

United Kingdom — GB CLP

• Regulation: Regulation (EC) No 1272/2008 as retained and amended (GB CLP)
• Authority: Health and Safety Executive (HSE)
• UN GHS revision aligned: Revision 7
• Scope: Substances and mixtures placed on the Great Britain market (England, Scotland, Wales). Northern Ireland follows EU CLP under the Windsor Framework.
• Language: English
• Current deadlines: GB CLP is in force. The four new EU hazard classes for endocrine disruptors and PMT/vPvM have not been adopted into GB CLP as of May 2026 — divergence is widening.

After Brexit, the UK retained CLP as domestic law but renamed it GB CLP. For Great Britain, HSE replaced ECHA as the regulator. The two regimes started identical in January 2021 but have begun to diverge. The 2023 EU additions for endocrine disruptors and PMT/vPvM were not adopted by GB. UK companies selling into both markets must therefore prepare two SDS variants — one with EUH statements and the new EU classes, one without.

Northern Ireland is the exception. Under the Windsor Framework, Northern Ireland continues to apply EU CLP for goods placed on its market. A label that satisfies GB CLP will not necessarily satisfy NI CLP after the EU adds new hazard classes.

Switzerland

• Regulation: Chemicals Ordinance (ChemO; SR 813.11)
• Authority: Federal Office of Public Health (FOPH)
• UN GHS revision aligned: Revision 7, harmonized with EU CLP
• Scope: Workplace and consumer chemicals
• Language: German, French, Italian (depending on canton)
• Current deadlines: Switzerland tracks EU CLP closely — ATP updates are typically transposed within 12 months of EU publication.

Switzerland is not an EU member but harmonizes its chemical regulations with CLP through bilateral agreements. The Chemicals Ordinance references EU CLP directly for classification criteria, hazard statements, and pictograms. Differences are minor and primarily linguistic — Swiss SDSs must be in the relevant national language for the canton of sale.

Asia-Pacific

China — GB 30000 Series

• Regulation: GB 30000.1-2024 (general rules, replaces GB 13690-2009); GB 30000.2-2013 through GB 30000.29-2013 (29 hazard-class standards); GB 30000.30-2025 for desensitized explosives; plus GB/T 17519 for SDSs and GB 15258 for labels
• Authority: Ministry of Industry and Information Technology (MIIT) for the GB 30000 standards; Ministry of Emergency Management (MEM) for production safety; Ministry of Ecology and Environment (MEE) for environmental classification; State Administration for Market Regulation (SAMR) for general supervision
• UN GHS revision aligned: Revision 8 in the new general-rules standard GB 30000.1-2024; Revision 4 in the older hazard-class standards GB 30000.2-29 (revisions in progress)
• Scope: All hazardous chemicals manufactured, used, or imported into China
• Language: Simplified Chinese mandatory; English permitted as supplemental
• Current deadlines: GB 30000.1-2024 entered into force on August 1, 2025, replacing the 2009 general-rules standard. GB 30000.30-2025 (desensitized explosives) takes effect July 1, 2026. Revisions of GB 30000.2 through GB 30000.29 to align with later UN GHS revisions are in progress.

China is in the middle of a major GHS update. The general-rules standard GB 30000.1-2024 was published on July 24, 2024 and took effect August 1, 2025, moving the framework from a UN GHS Revision 4 baseline (under the previous GB 13690-2009) to Revision 8. The 28 hazard-class standards GB 30000.2 through GB 30000.29 are still on Revision 4 and are being revised separately — the official roadmap commits to gradual alignment but has not published firm dates for each part. The newly issued GB 30000.30-2025 covers desensitized explosives and will take effect July 1, 2026.

The strict requirement for Simplified Chinese on every label and SDS means that an EU- or US-compliant label generally cannot be sold in mainland China without rework. China also operates the Hazardous Chemicals Catalogue (危险化学品目录, last updated 2015 but in active enforcement), which lists 2,828 substances subject to additional registration, transport, and storage requirements above the standard GB 30000 classification. Importing any chemical on this catalogue requires an additional safety registration with the National Registration Center for Chemicals (NRCC).

Japan — JIS Z 7252 and JIS Z 7253

• Regulation: JIS Z 7252:2019 (classification) and JIS Z 7253:2019 (labels and SDSs); enforcement through the Industrial Safety and Health Law (ISHL), the Poisonous and Deleterious Substances Control Law (PDSCL), and the PRTR Law
• Authority: Ministry of Health, Labour and Welfare (MHLW); Ministry of Economy, Trade and Industry (METI); Ministry of the Environment (MOE); coordinated by the National Institute of Technology and Evaluation (NITE)
• UN GHS revision aligned: Revision 6 in current JIS standards; revision to align with later UN GHS revisions is in formal preparation
• Scope: Industrial chemicals subject to ISHL (mandatory SDS and labeling list expanding April 2026)
• Language: Japanese mandatory on labels; SDSs accepted bilingually
• Current deadlines: ISHL amendment effective April 1, 2026 adds 779 chemical substances to the mandatory SDS and labeling list under the Cabinet Order of the Industrial Safety and Health Law. The same date introduces a new provision allowing substitute chemical names on SDSs to protect confidential business information for low-risk substances.

Japan splits chemical hazard regulation across three ministries, each enforcing a different aspect of the GHS framework. JIS Z 7252 and JIS Z 7253 are voluntary technical standards — but ISHL Article 57 makes label and SDS provision mandatory for any chemical on the designated list, and the JIS standards become the de facto compliance requirement.

The April 1, 2026 update is significant for two reasons. First, an additional 779 substances become subject to mandatory SDS and labeling — companies need to verify whether each substance in their inventory is on the expanded list. Second, MHLW finalized a new rule allowing substitute chemical names on SDSs for substances that meet specific low-risk criteria (excluding carcinogens, mutagens, reproductive toxicants, and acute toxicity Categories 1-3). This is intended to balance worker transparency against trade-secret protection. NITE maintains the GHS classification list (the “NITE-CHRIP” database) which serves as the authoritative source for Japanese GHS classifications.

South Korea

• Regulation: Industrial Safety and Health Act (K-OSHA) Article 110-114; Act on Registration and Evaluation of Chemicals (K-REACH); Chemical Substances Control Act (K-CSCA)
• Authority: Ministry of Employment and Labor (MoEL) for K-OSHA; Ministry of Environment for K-REACH
• UN GHS revision aligned: Revision 7
• Scope: Workplace chemicals (MoEL); environmental and consumer (Ministry of Environment); transport (Ministry of Land)
• Language: Korean mandatory on labels and SDSs
• Current deadlines: MoEL Public Notice No. 2023-9 governs current GHS classification and labeling; updates align with UN GHS Revision 7. K-REACH registration deadlines for substances above 1 ton/year were completed December 31, 2024; ongoing for new chemicals.

South Korea splits chemical compliance between two ministries with overlapping but distinct requirements. MoEL enforces workplace labels and SDSs through K-OSHA. The Ministry of Environment enforces K-REACH, which is closer to EU REACH than to the GHS framework — it requires pre-manufacture registration of chemicals exceeding 1 ton per year, with full data dossiers for substances above 100 tons.

For label and SDS purposes, K-OSHA Public Notice 2023-9 is the operative document. It specifies Korean-language labels with the standard nine UN GHS pictograms. South Korea does not enforce the new EU hazard classes for endocrine disruptors or PMT — but Ministry of Environment guidance has flagged endocrine disruptor screening as a priority for 2026-2028.

Indonesia

• Regulation: KEMENAKER Regulation No. PER.187/MEN/1999 on Hazardous Chemical Control; Permenperin No. 23/M-IND/PER/4/2013 on classification of industrial chemicals
• Authority: Ministry of Manpower (KEMENAKER); Ministry of Industry (Kementerian Perindustrian)
• UN GHS revision aligned: Revision 4 baseline; partial alignment with later revisions in industrial sector
• Scope: Industrial and workplace chemicals
• Language: Bahasa Indonesia mandatory on labels; SDSs accepted bilingually
• Current deadlines: GHS implementation has been mandatory for industrial chemicals since 2013 and for consumer chemicals since 2017. Updates to align with later UN GHS revisions are in technical consultation.

Indonesia is the largest ASEAN market for chemical compliance. The Ministry of Industry’s Permenperin 23/2013 made GHS classification mandatory for industrial chemicals — but enforcement is split with KEMENAKER, which handles workplace safety. Companies importing into Indonesia therefore prepare two parallel sets of documentation depending on the end use channel.

The mandatory Bahasa Indonesia language requirement is strict at customs. SDSs may be bilingual, but the label itself must be in Indonesian. The 2013 baseline aligned Indonesia with UN GHS Revision 4; subsequent updates have been partial. As of May 2026 there is no published timeline for moving to Revision 7 or later.

Australia and New Zealand

• Regulation (AU): Model Work Health and Safety (WHS) Regulations, Schedule 9
• Authority (AU): Safe Work Australia (model), state and territory regulators (enforcement)
• Regulation (NZ): Hazardous Substances and New Organisms (HSNO) Act; Hazardous Substances Regulations 2017
• Authority (NZ): Environmental Protection Authority (EPA NZ); WorkSafe New Zealand
• UN GHS revision aligned: Revision 7 (both countries)
• Scope: Workplace chemicals (AU); workplace, consumer, and environmental (NZ)
• Language: English
• Current deadlines: Both countries are in force on Revision 7. Australia transitioned from Revision 3 to Revision 7 with a phase-in completing January 1, 2023. New Zealand reached Revision 7 baseline in April 2021.

Australia operates a federation model: Safe Work Australia publishes the Model WHS Regulations, which each state and territory then adopts (with minor variations). The model regulations transitioned to UN GHS Revision 7 in 2017 with a five-year phase-in that ended January 1, 2023. Western Australia and Victoria each have their own implementing legislation, but the Schedule 9 classification rules are essentially identical across jurisdictions.

New Zealand uses a different statutory framework — the HSNO Act covers chemicals at a level above workplace use, including consumer products and environmental risk. EPA NZ maintains the New Zealand Hazardous Substances Classification database, which lists the GHS classification status of every approved substance. The 2017 Hazardous Substances Regulations brought NZ into Revision 7 alignment in April 2021.

Note on spelling: official Australian and New Zealand publications use the British spelling “harmonised,” not the American “harmonized.” A label or SDS using either spelling is generally accepted.

Philippines

• Regulation: DAO 2009-08 (Department of Environment and Natural Resources Administrative Order); Chemical Control Order (CCO) for specific listed substances
• Authority: Department of Environment and Natural Resources (DENR), Environmental Management Bureau (EMB)
• UN GHS revision aligned: Revision 4
• Scope: Industrial chemicals manufactured, imported, or distributed
• Language: English (Filipino accepted as supplemental)
• Current deadlines: GHS classification mandatory since 2015 for industrial chemicals. Revision update is in technical consultation.

The Philippines made GHS classification mandatory through DAO 2009-08, with full enforcement starting in 2015. The administrative order references UN GHS Revision 4. The DENR Environmental Management Bureau manages the Chemical Control Order list, which adds priority substances requiring additional reporting and risk management measures beyond standard GHS classification. As of 2026 there are 13 substances or substance groups under CCO, including asbestos, mercury, and certain ozone-depleting substances.

Thailand

• Regulation: Hazardous Substance Act B.E. 2535 (1992) as amended; Notification of the Ministry of Industry on the GHS System B.E. 2555 (2012)
• Authority: Department of Industrial Works (DIW); Food and Drug Administration (FDA); Department of Agriculture (DOA)
• UN GHS revision aligned: Revision 5
• Scope: Industrial, consumer, agricultural, and pharmaceutical chemicals — split across three agencies
• Language: Thai mandatory
• Current deadlines: Substance compliance from 2013; mixtures from 2017. Both phases are fully in force.

Thailand’s Hazardous Substance Act predates GHS by 20 years. GHS was overlaid onto the existing four-category hazard list (Types 1 through 4 by severity) through a 2012 Ministry of Industry notification. Thai labels must use Thai language and follow the Type-based registration tier — Type 4 substances (most hazardous) require a license to manufacture, import, or possess. The complexity of the system means most companies use a Thai regulatory consultant for first-time market entry.

Malaysia

• Regulation: Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013 — known as CLASS Regulations
• Authority: Department of Occupational Safety and Health (DOSH)
• UN GHS revision aligned: Revision 3
• Scope: Workplace chemicals
• Language: Bahasa Malaysia and English (bilingual)
• Current deadlines: CLASS 2013 is in force. An update to align with later UN GHS revisions has been in consultation since 2022.

Malaysia’s CLASS Regulations 2013 are the primary GHS instrument for workplace chemicals. The reference baseline is UN GHS Revision 3 — among the oldest still in force in the Asia-Pacific region. DOSH enforces classification, label, and SDS requirements with bilingual Bahasa Malaysia and English content. Updates to a later revision have been discussed since 2022 but no firm timeline has been published as of May 2026.

Vietnam

• Regulation: Decree 113/2017/ND-CP on chemical management; Circular 32/2017/TT-BCT on technical implementation; Law on Chemicals No. 69/2025/QH15 (effective January 1, 2026)
• Authority: Ministry of Industry and Trade (MoIT)
• UN GHS revision aligned: Revision 2 (with selective updates)
• Scope: Industrial chemicals subject to MoIT’s National Chemical Management Plan
• Language: Vietnamese mandatory
• Current deadlines: The new Law on Chemicals 69/2025/QH15 took effect January 1, 2026, replacing the 2007 framework. Implementing decrees are being drafted through 2026.

Vietnam codified GHS classification, labeling, and SDS requirements for industrial chemicals under Decree 113/2017. The reference baseline is older than most ASEAN neighbors — UN GHS Revision 2 with selective additions — which makes Vietnam’s labels visibly different from EU or US labels for the same substance. A new framework Law on Chemicals (No. 69/2025/QH15) entered into force on January 1, 2026 and signals a major overhaul of Vietnamese chemical management; specific GHS-related implementing decrees are expected through 2026.

India

• Regulation: Manufacture, Storage and Import of Hazardous Chemical (MSIHC) Rules, 1989 (as amended); Chemicals (Management and Safety) Rules — draft published 2020, not yet finalized
• Authority: Ministry of Environment, Forest and Climate Change (MoEFCC)
• UN GHS revision aligned: Voluntary; no mandatory national GHS framework
• Scope: Workplace and industrial chemicals subject to MSIHC Rules
• Language: English (Hindi widely used as supplemental)
• Current deadlines: The draft Chemicals (Management and Safety) Rules would mandate GHS classification when finalized. Status as of May 2026: still in inter-ministerial consultation since 2020.

India has been the slowest large economy to make UN GHS classification mandatory. The MSIHC Rules of 1989 govern hazardous chemical manufacture, storage, and import, but they pre-date GHS and use a different hazard schema. The draft Chemicals (Management and Safety) Rules — published in 2020 — would create an India REACH equivalent and mandate GHS classification, but six years later the rules remain in consultation. Most multinational companies operating in India voluntarily provide GHS-aligned labels and SDSs to facilitate global trade, but there is no statutory penalty for non-GHS labels.

Latin America

Brazil

• Regulation: ABNT NBR 14725:2023 (consolidating four previous parts); Resolution ANVISA RDC No. 222/2018 for healthcare workplace chemicals
• Authority: Associação Brasileira de Normas Técnicas (ABNT) for technical standard; Ministry of Labor for workplace enforcement; ANVISA for healthcare; IBAMA for environmental
• UN GHS revision aligned: Revision 7
• Scope: All chemical substances and mixtures placed on the Brazilian market
• Language: Portuguese mandatory
• Current deadlines: ABNT NBR 14725:2023 was published July 3, 2023 with a two-year transition period. The standard became mandatory on July 4, 2025. All SDSs and labels for the Brazilian market must comply with the new format from that date.

Brazil consolidated previously fragmented GHS guidance into ABNT NBR 14725:2023, replacing four separate parts of the 2009 standard with a single 520-page document. The new version moves Brazil from a UN GHS Revision 3 baseline to Revision 7, and introduces three notable changes: the SDS acronym changes from FISPQ to FDS (Ficha com Dados de Segurança), Section 1 must list a Brazilian 24-hour emergency contact number, and labels may include a QR code for SDS access. Portuguese-language labels and SDSs are mandatory; the Brazilian regulatory authority will not accept a Spanish-language SDS even from neighboring Mercosur countries. Brazil is the regulatory anchor for Mercosur GHS implementation, with Argentina, Paraguay, and Uruguay tracking Brazilian standards.

Mexico

• Regulation: NOM-018-STPS-2015 — Sistema armonizado para la identificación y comunicación de peligros y riesgos por sustancias químicas peligrosas en los centros de trabajo
• Authority: Secretaría del Trabajo y Previsión Social (STPS)
• UN GHS revision aligned: Revision 5
• Scope: Workplace chemicals only
• Language: Spanish mandatory
• Current deadlines: NOM-018-STPS-2015 in force since October 9, 2018. Update to a later revision has been in consultation since 2023.

Mexico’s NOM-018-STPS-2015 covers workplace chemicals under the Secretariat of Labor. The standard’s UN GHS Revision 5 baseline is shared with Thailand and is older than the OSHA HCS 2024 baseline — which means a US-compliant label is sometimes not directly accepted in Mexico without minor wording adjustments. The Spanish-language requirement is enforced; English-only labels fail customs inspections.

Argentina, Chile, Peru

• Regulation (AR): Resolution 801/2015 (occupational); Decree 1496/1992 for general chemical management
• Regulation (CL): Decree 57/2019 — applies UN GHS directly without national elaboration
• Regulation (PE): Supreme Decree 002-2018-SA — applies UN GHS directly with Spanish-language requirement
• Authority (AR): Ministry of Labor; SRT (workplace safety regulator)
• Authority (CL): Ministry of Health; Department of Workplace Safety
• Authority (PE): Ministry of Health; DIGEMID
• UN GHS revision aligned: Revision 6 to 7 (varies)
• Scope: Workplace and industrial chemicals
• Language: Spanish mandatory
• Current deadlines: All three countries are in force on their respective revisions.

Three Andean and Southern Cone economies that adopted UN GHS without major national modifications. Chile’s Decree 57/2019 is the most direct — it references UN GHS Revision 7 with no significant deviation. Peru’s Supreme Decree applies a similar approach. Argentina has additional layers from its older 1992 chemical management framework, which compliance officers need to check separately. All three require Spanish-language labels and SDSs; Brazilian Portuguese labels are not interchangeable.

MENA and Africa

GCC Region

• Regulation: GSO 2654:2021, updated to GSO 2654:2025 — Globally Harmonized System (GHS) in Gulf Cooperation Council (GCC) Countries
• Authority: GCC Standardization Organization (GSO), with national regulators in each member state (SASO in Saudi Arabia, ESMA in UAE, etc.)
• UN GHS revision aligned: Revision 10 (GSO 2654:2025 references the 2023 UN GHS edition)
• Scope: Industrial and consumer chemicals across all GSO member states. Saudi Arabia is exempt due to national legislation that conflicts with the regulation as a Gulf-wide technical regulation.
• Language: Arabic mandatory; English accepted as bilingual
• Current deadlines: GSO 2654:2021 was published in January 2022 and remains the implemented baseline. GSO 2654:2025 was approved for publication in December 2025; transposition into national legislation across member states is in progress.

The Gulf Cooperation Council adopted a unified GHS standard through GSO 2654:2021 — the first regional consolidation of GHS rules in the Middle East. The 2025 update (GSO 2654:2025) moves the baseline to UN GHS Revision 10 and is being adopted by member states sequentially. The standard requires bilingual Arabic and English content on labels and SDSs.

A practical complication: the Kingdom of Saudi Arabia is formally exempt from this Gulf-wide regulation because of pre-existing national legislation. Saudi suppliers must still comply with national rules from the Saudi Standards, Metrology and Quality Organization (SASO), which closely track but are not identical to the GSO standard. SASO is the most active enforcement agency in the region — inspectors at major Saudi ports check label compliance routinely. UAE, Kuwait, Qatar, Bahrain, and Oman apply GSO 2654 directly, with enforcement weight varying by member state. The mandatory Arabic translation is the single largest implementation barrier for non-Arabic-speaking suppliers entering the region.

Türkiye

• Regulation: SEA Yönetmeliği — Maddelerin ve Karışımların Sınıflandırılması, Etiketlenmesi ve Ambalajlanması Hakkında Yönetmelik (Regulation on Classification, Labelling and Packaging of Substances and Mixtures); KKDIK Regulation for chemical registration
• Authority: Ministry of Environment, Urbanisation and Climate Change (MoEUCC)
• UN GHS revision aligned: Revision 7, harmonized with EU CLP
• Scope: Substances and mixtures placed on the Turkish market
• Language: Turkish mandatory
• Current deadlines: SEA Yönetmeliği is in force. KKDIK pre-registration deadline for substances already on the Turkish market was October 31, 2025. Full registration deadlines are staged: December 31, 2026 for substances above 1,000 tons per year and for CMR Category 1A/1B above 1 ton; December 31, 2028 for 100-1,000 tons; December 31, 2030 for 1-100 tons.

Türkiye’s SEA Yönetmeliği is a near-direct transposition of EU CLP into Turkish national law. Classification criteria, hazard statements, and pictograms match EU CLP precisely — but the SDS and label must be in Turkish. KKDIK is Türkiye’s REACH equivalent, requiring registration of substances above 1 ton/year. The original 2023 registration deadline was extended through staged amendments in December 2023 and August 2025, giving companies until 2026, 2028, or 2030 depending on tonnage and hazard classification. SDSs must be prepared by a Certified Chemical Assessment Specialist (KDU) and uploaded to the Ministry’s official SDS Portal. Companies already CLP-compliant for EU markets typically need translation work plus KDU certification to meet Turkish requirements.

South Africa

• Regulation: Hazardous Chemical Substances Regulations under the Occupational Health and Safety Act, 1993; SANS 10234 (national standard for GHS classification)
• Authority: Department of Employment and Labour
• UN GHS revision aligned: Revision 7 (in transition from Revision 4)
• Scope: Workplace chemicals
• Language: English mandatory; other South African official languages accepted as supplemental
• Current deadlines: Updated Hazardous Chemical Substances Regulations published 2021; full transition to UN GHS Revision 7 baseline through 2025-2026.

South Africa has been moving from a UN GHS Revision 4 baseline (in SANS 10234:2008) to Revision 7 (SANS 10234:2019) since 2021. The transition is staged: new chemicals must comply with the updated standard from 2024; existing chemical inventories have until end-2026 to align. The Department of Employment and Labour enforces through routine workplace inspections. South Africa is the regulatory anchor for Southern African Development Community (SADC) chemical management, with neighboring countries either adopting SANS standards directly or referencing UN GHS without national elaboration.

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Common pitfalls and FAQ

What does GHS stand for?

GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. It is a UN-published framework — not a regulation by itself — that defines uniform criteria for classifying chemical hazards and standardized formats for hazard communication on labels and Safety Data Sheets (SDSs). Each country implements GHS through its own national legislation, which is why a chemical can be regulated differently in two markets that both claim to “follow GHS.”

What is the difference between GHS and an SDS?

GHS is the system. The Safety Data Sheet (SDS) is one of the outputs that GHS specifies. GHS defines the 16-section structure that every SDS must follow worldwide: identification, hazards, composition, first-aid, firefighting, accidental release, handling and storage, exposure controls, physical and chemical properties, stability, toxicology, ecology, disposal, transport, regulatory information, and other information. Before GHS, there was no global standard for SDS structure — every country had its own format. Today an SDS authored under EU CLP, US OSHA HCS, or Japanese JIS will share the same 16-section framework, even if the data inside differs.

Is a single Safety Data Sheet valid worldwide?

No. The 16-section SDS structure is universal, but the content of each section depends on which national regulation applies. A US OSHA HCS SDS will not include aquatic toxicity in Section 12 because OSHA does not regulate environmental hazards; an EU CLP SDS for the same chemical will include it. A Brazilian SDS must list a Brazilian emergency phone number. A Korean SDS must be in Korean. A Saudi SDS must be in Arabic and English. Most multinational manufacturers maintain a master SDS in English and produce localized variants for each destination market, often through specialized SDS-authoring software that handles the per-country logic automatically.

Why are GHS revisions different in different countries?

A new UN GHS revision is published every two years. Adopting it requires national legislation, which usually takes 2-5 years of consultation, drafting, and parliamentary or ministerial approval. Each country prioritizes differently. The EU adopts most revisions quickly through CLP Adaptations to Technical Progress. The US moved from Revision 3 (2012) to Revision 7 only in 2024 — a 12-year gap. Some markets remain on older revisions for cost or capacity reasons. The result is that the “globally harmonized” system has 6 to 8 effective revisions in active use at any moment.

How do I track GHS revisions across markets?

Three sources are reliable. UNECE publishes the Purple Book itself and the meeting reports of UNSCEGHS. National regulators (ECHA, OSHA, NITE, MoEL, MEE, etc.) publish their adoption notices in their official gazettes. Industry trade associations such as the American Chemistry Council, Cefic, and the Asia Pacific Chemical Industry Council publish summaries that compare national adoption status. For a country-by-country reference of the current implementation status, the GHS Pictograms compliance hub maintains a live tracker.

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How GHS Pictograms tools help

Two tools on this site address the most common pain points in multi-market GHS compliance:

• Label Constructor — Build a fully compliant chemical label by selecting hazard classes and signal words. The tool automatically generates the correct UN GHS pictograms in the correct sizes for your container volume, deduplicates precautionary statements, and produces a print-ready output. Useful when you need to produce a label that satisfies both your home market and an export market with overlapping hazard requirements.

• ATE Calculator — Compute the Acute Toxicity Estimate for a mixture using the GHS additivity formula. The calculator handles the strict cut-off values that EU CLP applies and shows how the same mixture would be classified under different jurisdictions. Useful when reviewing a formulation for first-time market entry into a country with different mixture rules.

For underlying chemical hazard data, the GHSSymbols.com hazards database covers 4,178 substances with their CLP Annex VI harmonized classifications. Each substance page lists hazard classes, H and P statements, pictograms, signal word, and the source CLP Annex VI entry.

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Key takeaways

• UN GHS is a framework, not a global law. Every country implements it through its own legislation, with its own building block selections, language requirements, and revision baseline. Compliance is always per-market.

• Revision 7 is the most widely implemented baseline in 2026. OSHA HCS 2024, GB CLP, Canadian WHMIS 2015, Brazilian ABNT NBR 14725:2023, GCC GSO 2654:2021, Australia, New Zealand, and South Korea all converge on Revision 7. Mismatches still exist with markets on Revision 4 (Indonesia, Philippines, China’s older standards) or Revision 5 (Mexico, Thailand).

• EU CLP is the most aggressive implementation. The EU adds hazard classes ahead of UN consensus — endocrine disruptors, PBT/vPvB, PMT/vPvM in 2023, with a four-stage transition running through May 2028. UK GB CLP has not adopted these and is diverging from EU CLP since 2024.

• 2026 is a high-deadline year. OSHA HCS substances become mandatory May 19, 2026. EU CLP existing substances must comply with new hazard classes by November 1, 2026. Japan’s ISHL adds 779 substances April 1, 2026. China’s GB 30000.30 takes effect July 1, 2026. Compliance teams need to track all of these in parallel.

• Language requirements are non-negotiable. Brazilian Portuguese, French (Canada), Arabic (GCC), Korean, Japanese, Bahasa Indonesia, Thai, Turkish, and Vietnamese are all mandatory on labels for their respective markets. English-only labels fail customs in most non-English markets.

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Related articles in this hub

• UN GHS pillar overview — what UN GHS is, how UNSCEGHS maintains it, and how the building block approach works in detail
• EU CLP Regulation pillar — full breakdown of CLP including ATPs, EUH statements, and the 2023 hazard classes for endocrine disruptors and PMT/vPvM
• OSHA HCS 2024 pillar — complete guide to the United States Hazard Communication Standard, including the January 2026 deadline extension
• Global GHS implementation — deeper coverage of GHS implementations in Asia-Pacific, Latin America, MENA, and Africa

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Sources

• United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev. 11, 2025). ST/SG/AC.10/30/Rev.11. Published September 12, 2025. Available at: https://unece.org/transport/dangerous-goods/ghs-rev11-2025
• US Occupational Safety and Health Administration, Hazard Communication Standard; Final Rule, 29 CFR 1910.1200, 89 FR 44144. Published May 20, 2024. Compliance dates extended by 91 FR 1696, January 15, 2026. Available at: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
• European Parliament and Council, Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP). Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R1272-20250101
• European Commission, Commission Delegated Regulation (EU) 2023/707 of 19 December 2022 amending Regulation (EC) No 1272/2008 as regards hazard classes and criteria. Published in the Official Journal on March 31, 2023. Available at: https://eur-lex.europa.eu/eli/reg_del/2023/707/oj
• European Chemicals Agency (ECHA), New hazard classes 2023. Guidance on transition periods for substances and mixtures. Available at: https://echa.europa.eu/new-hazard-classes-2023
• Health Canada, Hazardous Products Regulations (SOR/2015-17) under the Hazardous Products Act. Available at: https://laws-lois.justice.gc.ca/eng/regulations/SOR-2015-17/
• UK Health and Safety Executive, Classification, Labelling and Packaging of Chemicals (GB CLP). Available at: https://www.hse.gov.uk/chemical-classification/legal/clp-regulation.htm
• Standardization Administration of China, GB 30000.1-2024 Specification for Classification and Labelling of Chemicals — Part 1: General Rules. Effective August 1, 2025.
• Japan Ministry of Health, Labour and Welfare, Industrial Safety and Health Law (ISHL); JIS Z 7252:2019 and JIS Z 7253:2019. National Institute of Technology and Evaluation (NITE) GHS classification database NITE-CHRIP available at: https://www.nite.go.jp/en/chem/chrip/chrip_search/systemTop
• South Korea Ministry of Employment and Labor, MoEL Public Notice No. 2023-9 on Classification, Labelling and Material Safety Data Sheet of Chemicals.
• Brazilian Association of Technical Standards (ABNT), NBR 14725:2023 — Chemicals: Information about safety, health and environment — General aspects of GHS, classification, SDS and labelling of chemicals. Mandatory effective July 4, 2025.
• Mexican Secretariat of Labor and Social Welfare, NOM-018-STPS-2015 — Sistema armonizado para la identificación y comunicación de peligros y riesgos por sustancias químicas peligrosas en los centros de trabajo. In force since October 9, 2018.
• Safe Work Australia, Model Work Health and Safety Regulations, Schedule 9. Available at: https://www.safeworkaustralia.gov.au/law-and-regulation/model-whs-laws
• New Zealand Environmental Protection Authority, Hazardous Substances Regulations 2017 under the Hazardous Substances and New Organisms Act. Available at: https://www.epa.govt.nz/industry-areas/hazardous-substances/
• GCC Standardization Organization, GSO 2654:2021 (and 2025 revision) — Globally Harmonized System (GHS) in Gulf Cooperation Council (GCC) Countries. Available at: https://www.gso.org.sa/
• Republic of Türkiye, SEA Yönetmeliği — Regulation on Classification, Labelling and Packaging of Substances and Mixtures; KKDIK Regulation. Ministry of Environment, Urbanisation and Climate Change. Available at: https://kimyasallar.csb.gov.tr/
• Department of Employment and Labour, Republic of South Africa, Hazardous Chemical Substances Regulations under the Occupational Health and Safety Act; SANS 10234.
• Substance classification data sourced from the GHSSymbols.com Hazards Database, derived from ECHA CLP Annex VI list of harmonised classifications, last synchronized May 2026.