GHS Label Requirements Compared: EU CLP, US HazCom 2024 and China GB 15258
"GHS" makes it sound like one label works everywhere. It does not. GHS is a UN framework that each jurisdiction adopts with its own revision level, language rules and added elements. If you export chemicals to more than one market, you are usually managing three label templates, not one. This is a comparison of the three markets most label printers see: the EU, the US and China.
Key points
- The six GHS elements are common; each jurisdiction adds its own: EU supplier block and size table, US SDS linkage and 2024 Rev. 7 alignment, China Chinese-language text and a 24 h emergency number.
- Revision levels differ: EU CLP tracks GHS via ATPs (Rev. 8/9 elements), US HazCom 2024 = Rev. 7 (+ some Rev. 8), China GB 30000-2013 = Rev. 4.
- US deadlines: substances 19 May 2026, mixtures 19 Nov 2027.
- China: label in Chinese, 24 h emergency phone (a domestic number for imports), reference to the SDS.
1. The six elements everyone shares
- Product identifier — chemical name or trade name plus the identity of hazardous ingredients where required.
- Hazard pictograms — black symbol on white, red diamond frame.
- Signal word — Danger or Warning.
- Hazard statements — H-codes.
- Precautionary statements — P-codes.
- Supplier identification — name, address, telephone.
2. Side-by-side
| EU — CLP (Reg. 1272/2008) | US — OSHA HazCom (2024 final rule) | China — GB 15258-2009 / GB 30000 series | |
|---|---|---|---|
| GHS revision | Tracks GHS through ATPs; currently includes elements up to Rev. 8/9 | Rev. 7 with selected Rev. 8 provisions (from 19 Jul 2024) | Rev. 4 (GB 30000-2013); GB 15258 revision in progress |
| Language | Official language(s) of the member state(s) where placed on the market | English; other languages may be added | Chinese mandatory; other languages allowed, not larger than Chinese |
| Emergency telephone | Not a label element (goes on SDS) | Not a label element (goes on SDS) | Required on the label: 24 h emergency number; imports need at least one mainland China number |
| Reference to SDS | Not required on label | Not required on label | Required phrase directing the user to the SDS |
| Label size rules | Annex I 1.2.1 table by package capacity (52×74 to 148×210 mm) | No fixed dimensions; must be legible; small-container provisions codified in 2024 | GB 15258 §5.3 table by container volume (50×75 to 200×300 mm); simplified label ≤ 100 mL |
| Pictogram size | ≥ 1/15 of minimum label area, never < 1 cm² | Legible; no minimum dimension in the standard | Per GB 20576–20602 pictogram standards |
| Ordering of statements | Free within the block; language groups together | Free | Physical → health → environmental hazards; signal word 'Danger' suppresses 'Warning' |
| Key deadline | Ongoing ATP updates | Substances 19 May 2026; mixtures 19 Nov 2027 | New GB 15258 expected; watch for transition period |
3. EU — what CLP adds
- Supplier block with name, address and telephone number of the supplier in the EU.
- Nominal quantity of the substance or mixture for consumer packages.
- Supplemental information (EUH statements) where classification triggers them.
- Size table — the only one of the three jurisdictions with fixed minimum dimensions, detailed in GHS label minimum size by container volume.
- Small packages (≤ 125 mL) may omit certain H/P statements for specific hazard classes under Annex I 1.5.2.
4. US — what HazCom 2024 changes
OSHA's final rule was published on 20 May 2024 and took effect on 19 July 2024. Highlights for labels:
- Alignment with GHS Revision 7 plus selected Revision 8 provisions (e.g. aerosols split into categories, desensitized explosives, non-animal testing language).
- Label compliance is tied to the date the product is released for shipment, not the date it is received.
- Codified rules for small containers (≤ 100 mL and ≤ 3 mL) allowing reduced label content with the full information on the outer packaging.
- Updated provisions for labels on bulk shipments.
- Deadlines: substances by 19 May 2026 (employer workplace updates by 20 July 2026); mixtures by 19 November 2027 (employer updates by 19 July 2028).
5. China — what GB 15258 adds
- Chinese language is mandatory. Bilingual labels are common for exports into China; the foreign-language text must not be larger than the Chinese.
- 24-hour emergency telephone number on the label. For imported chemicals, at least one number must be located in mainland China.
- Reference phrase telling the user to consult the safety data sheet (SDS/化学品安全技术说明书).
- Hazard ordering: physical hazards first, then health, then environmental; only one signal word, with "Danger" (危险) overriding "Warning" (警告).
- Size table by container volume and a simplified label for packages ≤ 100 mL.
Classification is the hidden difference. Because the three jurisdictions sit on different GHS revisions, the same substance can carry a different category — and therefore different pictograms and statements — in each market. Start from the classification, not from the label template.
6. Managing three templates
- Classify per jurisdiction (or confirm your supplier's classification matches the destination revision).
- Keep the pictogram, signal word and H/P block as a shared core; keep supplier, emergency and language blocks per market.
- Check size against the EU table and the China table; the US has no table but must be legible.
- For China, add the emergency number and the SDS reference phrase; for the EU, add nominal quantity and EU supplier; for the US, confirm the SDS matches the label and the release-for-shipment date.
Build the label from the UN number
Enter a UN number and the generator fills pictograms, signal word and H/P statements; then adjust supplier and emergency blocks for each market. Open the tool →
References
This article is based on the following primary sources; always check the edition in force before shipping or labelling.
- UNECE — Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
- UNECE — GHS pictograms (official artwork)
- EUR-Lex — Regulation (EC) No 1272/2008 (CLP)
- ECHA — Labelling and packaging under CLP
- OSHA — Hazard Communication Standard (29 CFR 1910.1200)
- Federal Register — Hazard Communication Standard final rule (May 20, 2024)
Frequently asked questions
Are GHS labels the same in every country?
No. GHS is a UN framework; each jurisdiction adopts a version of it with its own additions. The six core elements (product identifier, pictograms, signal word, hazard statements, precautionary statements, supplier identification) are common, but the EU adds a CLP-specific supplier block and label-size rules, the US ties the label to the SDS and the 2024 GHS Rev. 7 alignment, and China requires Chinese-language text, a 24-hour emergency telephone number, and the reference phrase to the safety data sheet.
What changed with OSHA's 2024 HazCom update?
OSHA published the final rule on 20 May 2024 (effective 19 July 2024) aligning HazCom with GHS Revision 7 and parts of Revision 8. Compliance dates: substances by 19 May 2026 (employers update workplace labels, programmes and training by 20 July 2026); mixtures by 19 November 2027 (employers by 19 July 2028). Labels are now tied to the date the product is released for shipment, and the rule codifies small-container labelling and bulk shipment rules.
Does a China GHS label have to include an emergency telephone number?
Yes. GB 15258-2009 requires a 24-hour chemical emergency telephone number; for imported chemicals at least one of those numbers must be a number inside mainland China. The label must be in Chinese, and other languages may be added as long as they are not larger than the Chinese text.
Can I use one label for the EU, the US and China?
In practice, rarely. Language alone rules it out for China. Between the EU and the US you can often share pictograms, signal word and H/P statements if the classifications agree, but the supplier block, the emergency information and the label-size rules differ, and the classification itself may differ because the jurisdictions are on different GHS revisions.