GHS Label and Transport Hazard Label on the Same Package: CLP Article 33, HazCom vs DOT, Sizes and Placement on Drums, IBCs and Cartons
The GHS label tells the person who opens the container what the chemical does to them. The transport label tells the driver, the port and the emergency responder what the package does in a crash or a fire. They come from different regulators, use different pictograms, and both have to be on the outside of the drum, IBC or carton that leaves your dock. This guide sorts out which elements each regime requires, where one may stand in for the other, how big everything must be, and how to fit it all on a 200 L drum without covering one label with another.
Key points
- Two regimes, both apply: supply (GHS via EU CLP or US HazCom) and transport (ADR / IMDG / IATA / 49 CFR). Neither replaces the other.
- EU CLP Art. 33: on outer packaging with transport labels, the GHS pictogram for the same hazard may be omitted; inner packagings carry the full CLP label; single packagings carry both sets.
- US: HazCom 2012 forbade the OSHA pictogram next to a DOT label for the same hazard; HazCom 2024 allows both.
- Transport label 100 × 100 mm; UN number letters 12 mm over 30 L/30 kg, 6 mm at or below; environmentally hazardous mark 100 × 100 mm; limited-quantity mark 100 × 100 (min 50 × 50).
- IBCs over 450 L: labels on two opposite sides. Sea freight: labels must survive three months in seawater — use BS 5609 stock.
1. What each regime puts on the package
| Element | Supply label (GHS: CLP / HazCom) | Transport (ADR / IMDG / IATA / 49 CFR) |
|---|---|---|
| Identification | Product identifier, supplier name / address / phone | UN number with 'UN' prefix; proper shipping name (IMDG, IATA and 49 CFR always; ADR on the transport document, on the package for some cases) |
| Hazard pictograms | GHS diamonds: red border, black symbol, white background | Class labels: 100 × 100 mm diamonds with class number in the bottom corner, colour-coded by class |
| Words | Signal word (Danger / Warning), H statements, P statements | None on the label except class-specific text; PSN and technical name in the marking where required |
| Extra marks | Supplemental information; tactile warning on consumer packs (EU) | Environmentally hazardous mark, limited quantity mark, orientation arrows, overpack marking, salvage packaging marking |
| Size rule | Label area by container volume (CLP Annex I 1.2.1; see the size table article) | Fixed: 100 × 100 mm labels, letter heights by package size |
The pictograms look alike but are not interchangeable: the GHS flame has a red frame on white, the Class 3 transport diamond is a red field with a white or black flame and a '3'. A shipper who prints only the transport diamond has not made a GHS label, and one who prints only the GHS label has not marked a dangerous goods package.
2. Where one may stand in for the other
EU — CLP Article 33
- Outer packaging with transport labels (33(1)): the GHS pictograms for the same hazard need not be repeated. The rest of the CLP label is also not required on the outer packaging, because the inner packagings carry it — but many shippers add the product name and supplier anyway.
- Inner packaging (33(2)): always the full CLP label.
- Single packaging such as a drum, IBC or jerrican (33(3)): both the CLP label and the transport elements. Where a transport label shows the same hazard as a CLP pictogram, the CLP pictogram may be omitted — and in practice usually is, to save space.
United States — HazCom and 49 CFR
HazCom 2012 Appendix C.2.3.3 said that where a DOT pictogram appeared on a shipped container, the OSHA pictogram for the same hazard shall not appear. That produced US-specific outer labels with the flame missing. OSHA's May 2024 final rule revised the provision so that both pictograms may appear together. If your artwork still deletes the GHS pictogram to satisfy the old rule, it is no longer necessary, and a single global outer label design is now possible. DOT labels themselves are governed by 49 CFR 172 Subpart E and match the UN diamonds in size and design.
Same hazard is judged by hazard, not by picture. A Class 3 diamond covers the GHS flame for flammability; it does not cover the health-hazard or corrosion pictograms on the same product. Those stay.
3. Transport elements: sizes
| Element | Size | Rule and notes |
|---|---|---|
| Class hazard label | 100 × 100 mm, line 5 mm inside the edge, class number in the bottom corner | ADR 5.2.2.2.1.1; may be reduced only if the package is too small, remaining clearly visible. Two or more labels side by side, not overlapping |
| UN number marking | 'UN' + 4 digits; character height ≥12 mm (package >30 L or >30 kg), ≥6 mm (≤30 L / 30 kg), any legible size (≤5 L / 5 kg) | ADR 5.2.1.1; IMDG 5.2.1.1 and IATA add the proper shipping name next to it; 49 CFR 172.301 requires PSN and UN number |
| Environmentally hazardous substance mark | 100 × 100 mm (fish and tree) | For UN 3077 / 3082 and any substance meeting the criteria; not required on single or inner packagings ≤5 L (liquid) or ≤5 kg (solid) |
| Limited quantity mark | 100 × 100 mm; may be reduced to 50 × 50 mm | Black top and bottom corners on white; 'Y' in the centre for air (IATA) |
| Orientation arrows | Two arrows on two opposite vertical sides | Combination packagings with liquid inner packagings; ISO 780 arrow |
| 'OVERPACK' | Letters ≥12 mm | On overpacks, plus repetition of any marks and labels not visible from outside |
| IBC (>450 L) labels | As above | Marks and labels on two opposite sides (ADR 5.2.2.1.7) |
Labels go on the same surface as the UN number marking if the package dimensions allow, near it, and never on the bottom. On a drum that means the side wall, upright, so that the diamond reads as a diamond when the drum stands. On cartons, one label per required class on one side, with the UN number and PSN alongside.
4. Durability
Every transport mode requires marks to withstand the journey without loss of legibility. Sea is the strictest: the IMDG Code requires that marks and labels remain identifiable after three months' immersion in seawater. The industry answer is BS 5609: section 2 certifies the label stock (face material plus adhesive) for adhesion and legibility after immersion; section 3 certifies the printed label, including the print method and ribbon. Polyester or polyethylene faces with marine adhesive, printed by thermal transfer with a resin ribbon, are the standard combination. Paper labels, direct-thermal stock and untested inks fail, whatever the design says.
Chemical resistance matters for the GHS half too: a drum of solvent that weeps at the bung will dissolve a paper label in a week. Match the label material to the product — the GHS size and material article covers stock selection for drums and bottles.
5. A placement plan for a 200 L drum
UN 1993 flammable liquid, Packing Group II, also toxic to aquatic life (H411), shipped by road and sea inside the EU:
- GHS panel: product identifier, supplier, signal word Danger, H225 / H411 and the P statements, GHS09 environment pictogram, any health pictograms. The GHS02 flame is omitted under CLP Art. 33(3) because the Class 3 diamond shows the same hazard. Panel sized to the CLP table for a container over 50 L — the size table article has the figures.
- Transport block next to it on the same wall: 'UN 1993' with the proper shipping name and technical name, letters ≥12 mm; Class 3 diamond 100 × 100 mm; environmentally hazardous mark 100 × 100 mm.
- Material: BS 5609 polyethylene face, resin ribbon, applied to the clean drum wall above the rolling hoop so it is not scuffed during handling.
- Check: nothing covers the UN certification embossing on the drum head; the GHS panel and the transport block do not overlap; both read upright when the drum stands.
The same product in 1 L bottles in a carton of 12: full CLP label on each bottle; carton carries UN 1993, PSN, Class 3 diamond, EHS mark (the bottles are 1 L, so the mark is not needed on them but is on the outer), orientation arrows on two sides — and no GHS pictogram, under Art. 33(1). If the consignment qualifies as limited quantity, the LQ mark replaces the class label and the UN marking on the carton.
Build the GHS half from the classification or UN number
Enter the UN number or GHS classes; the generator picks pictograms, signal word and H/P statements, sizes the label to the CLP table and exports SVG, PNG or PDF. Use the checklist to confirm the transport elements are present. Open the tool →
References
- Regulation (EC) No 1272/2008 (CLP), Article 33 — specific rules for labelling of outer, inner and single packaging
- OSHA Hazard Communication Standard 29 CFR 1910.1200, Appendix C (2024 final rule)
- ADR 2025, Part 5 — marking and labelling of packages (5.2.1, 5.2.2)
- IMDG Code, Chapter 5.2 — marking and labelling of packages including durability
- 49 CFR Part 172, Subparts D and E — marking and labeling
Frequently asked questions
Do I need both a GHS label and a transport diamond on a drum?
Yes, for a single packaging like a 200 L drum that is both the supply container and the transport package. The drum carries the full GHS label (product identifier, pictograms, signal word, hazard and precautionary statements, supplier) and the transport elements (UN number, proper shipping name where required, class label, marks). Under CLP Article 33 you may omit a GHS pictogram whose hazard is already shown by the transport label — for instance the flame pictogram next to a Class 3 diamond — but nothing else drops out.
Can the GHS pictogram be left off the outer carton?
In the EU, yes when the outer packaging carries transport labels: CLP Article 33(1) says the GHS pictograms for the same hazards need not appear on the outer packaging, though they may. The inner packagings inside must still carry full CLP labels. If the outer packaging has no transport labels — a small consignment below dangerous-goods thresholds — it needs the CLP label like any other package.
What size must the transport hazard label be?
The diamond is 100 × 100 mm minimum with a line 5 mm inside the edge and the class number in the bottom corner (ADR 5.2.2.2.1.1; IMDG and IATA are aligned). It may be reduced only if the package is too small to carry it, and must then remain clearly visible. The UN number is preceded by 'UN' in characters at least 12 mm high on packages over 30 L or 30 kg, at least 6 mm at 30 L/30 kg or less, and any legible size at 5 L/5 kg or less.
What changed for DOT labels and GHS pictograms in HazCom 2024?
HazCom 2012 (Appendix C.2.3.3) said that where a DOT pictogram appeared on a shipped container, the OSHA pictogram for the same hazard must not appear. OSHA's May 2024 final rule reversed that: both may now appear together. Shippers who used to design separate US and EU outer labels to avoid the conflict can now use one design.
What label material do I need for chemicals shipped by sea?
The IMDG Code requires that marks and labels stay legible after three months' immersion in seawater. In practice that means BS 5609-certified label stock — usually a polyester or polyethylene face with a marine-grade adhesive — and, for section 3 of the standard, a certified print method (thermal-transfer resin ribbon or approved inks). Paper labels and standard direct-thermal stock do not qualify.