GHS

The Globally Harmonized System is the United Nations framework for classifying and labelling chemicals based on physical, health, and environmental hazards. GHS provides standardised hazard classes (with criteria), label elements (pictograms, signal words, hazard statements, precautionary statements), and Safety Data Sheet structure. It was first published in 2003 and is now in its tenth revised edition (2023). Major jurisdictions including the EU (via CLP), the US (via OSHA HCS), China (via GB/T 17519), Australia (via Safe Work Australia / HCIS), and Korea (via MOEL standards) have all adopted GHS in jurisdiction-specific implementations.

What GHS standardised

Before GHS, chemical hazard classification was a patchwork. The same substance could be classified differently in the EU, the US, Japan, and China. The same hazard could trigger different label elements in different countries. SDSs followed different formats. GHS replaced this with:

• A common set of hazard classes, physical (flammability, oxidising, explosive, etc.), health (acute toxicity, skin corrosion, carcinogenicity, etc.), environmental (aquatic toxicity, ozone-depleting)
• Standardised hazard categories within each class (e.g. Acute Toxicity Category 1 to 5, with specific LD50 cutoffs)
• A single set of label elements: nine pictograms, two signal words (“Danger” or “Warning”), numbered H-codes for hazard statements, numbered P-codes for precautionary statements
• A 16-section SDS structure with mandatory content per section

The harmonisation allows a single hazard classification to map cleanly across most adopting jurisdictions, with variations in jurisdiction-specific exposure limits, regulatory cross-references, and labelling language.

GHS pictograms

Nine pictograms cover the GHS hazard universe:

Each pictogram is a red-bordered diamond on white background with a black symbol. The colour and shape are part of the standard, a black-bordered diamond is non-compliant.

H- and P-codes

Hazard statements are coded H followed by three digits. The first digit indicates the hazard family:

• H2xx = physical hazards (e.g. H225 = highly flammable liquid and vapour)
• H3xx = health hazards (e.g. H319 = causes serious eye irritation; H351 = suspected of causing cancer)
• H4xx = environmental hazards (e.g. H410 = very toxic to aquatic life with long-lasting effects)

Precautionary statements are coded P followed by three digits, organised by purpose:

• P1xx = general (e.g. P102 = keep out of reach of children)
• P2xx = prevention (e.g. P210 = keep away from heat, sparks, open flames, hot surfaces)
• P3xx = response (e.g. P305+P351+P338 = if in eyes, rinse cautiously with water for several minutes, remove contact lenses if present)
• P4xx = storage (e.g. P403 = store in a well-ventilated place)
• P5xx = disposal (e.g. P501 = dispose of contents/container in accordance with local regulations)

The P-codes can be combined (P305+P351+P338 is a single combined statement). The combinations are themselves standardised in GHS Annex 3.

Jurisdictional differences

GHS allows each adopting jurisdiction to make some choices. The key differences a chemical importer encounters:

• EU CLP has adopted some hazard categories the US has not (e.g. additional aquatic toxicity sub-categories) and adds the SVHC framework for Substances of Very High Concern
• US OSHA HCS is more lenient on environmental hazard classification (Section 12 of the SDS is less strictly enforced than in the EU)
• China GB/T 17519 uses the GHS framework but has a few China-specific add-ons in Section 15 (regulatory information) and in workplace exposure limits
• Australia HCIS generally accepts EU CLP or US OSHA SDSs but applies Safe Work Australia exposure standards in Section 8
• Korea has additional precursor control overlays for certain hazardous classes

For cargo crossing multiple jurisdictions, the importer must make sure the SDS in use at each destination matches that jurisdiction’s GHS implementation.

What GHS does not do

GHS is a classification and labelling framework. It does not:

• Determine import licensing or registration requirements (REACH, TSCA, and equivalent inventories handle that)
• Set workplace exposure limits (each jurisdiction’s occupational health authority does)
• Override transport classification (IMDG for sea, IATA for air, ADR for road), though GHS, IMDG, and IATA classifications align closely
• Specify which substances require an SDS (each jurisdiction sets its own threshold, typically based on classified hazards)

Operator note: revisions and the “lagging adoption” problem

GHS is revised every two years (the “GHS Revisions”). Each adopting jurisdiction picks up the new revisions on its own schedule, there is no automatic alignment. As of 2026 the EU is largely on Revision 9, the US on Revision 7, China on Revision 8, Australia on Revision 7. A substance newly classified in Revision 10 may not appear in any jurisdiction’s regulation for 1 to 3 years.

Practical implication: a Chinese factory’s SDS may be fully GHS Revision 8 compliant for China but missing EU CLP-specific elements that became mandatory under a later EU adoption of GHS Revision 9. Always commission a destination-jurisdiction-specific SDS rather than accepting the China-format GHS SDS as universal.

Related terms

SDS is the document that carries GHS classification at the per-product level. MSDS is the predecessor format GHS replaced. CLP is the EU implementation. GHS pictograms, hazard statement, precautionary statement, and signal word are the label elements GHS standardised.