Chemical Labeling and SDS Requirements in the United Nations

The United Nations does not impose a single worldwide chemical labeling law. Instead, the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS), maintained through the United Nations Economic Commission for Europe (UNECE), provides the international framework used by many countries and regions to develop their own hazard communication rules. The GHS establishes harmonized hazard classification criteria and communication elements for labels and Safety Data Sheets (SDSs). Governments decide how, where, and which revision of the GHS to implement. A product that follows the UN GHS is not automatically compliant in every country.

The current UN publication is GHS Revision 11, published in 2025. Revision 11 incorporates amendments adopted in December 2024, including changes and clarifications concerning aerosols and chemicals under pressure, non-animal methods for skin sensitization, hazards related to global warming, precautionary statements, and guidance on simple asphyxiants. Companies operating internationally should use the UN GHS as the technical foundation for hazard communication while separately checking the binding requirements of every destination market.

The following countries not otherwise covered in our country-specific blogs have been identified by UNECE as having information available regarding GHS implementation. Requirements and the extent of implementation may vary significantly by country and sector.

Argentina, Armenia, Belarus, Bolivia, Cambodia, Costa Rica, Côte d’Ivoire, Croatia, Democratic Republic of the Congo, Ecuador, Gambia, Ghana, Guatemala, Guinea, Honduras, Iceland, Kazakhstan, Kenya, Kyrgyzstan, Lao People’s Democratic Republic (Laos), Liechtenstein, Madagascar, Mauritius, Montenegro, Myanmar, Nigeria, Norway, Paraguay, Peru, Senegal, Serbia, Switzerland, Tunisia, Ukraine, Uruguay, Vietnam, and Zambia.

SDS Requirements

The GHS provides a standardized 16-section SDS format intended to communicate chemical hazards consistently throughout the supply chain.

Annex 4 of the GHS gives detailed guidance for preparing SDSs. The sections cover:

1. Identification
2. Hazard identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information, including the date of preparation or revision

Under the UN framework, an SDS should provide the applicable and available information under the relevant headings and should not simply leave information fields blank. The GHS also links SDS hazard information to the classification and label elements for the substance or mixture. However, the UN itself does not set a universal SDS language, supplier-address, emergency-number, revision-frequency, or national submission requirement. Those obligations arise when a country or regional authority implements the GHS through legislation. An SDS prepared for one jurisdiction may therefore require classification, wording, language, exposure limits, regulatory references, or other changes before it can be supplied in another market.

Consumer Label Requirements

The GHS contains harmonized label elements that may be used for hazardous chemicals, including a product identifier, supplier identification, hazard pictograms, a signal word, hazard statements, and precautionary statements as applicable to the classification. Annex 7 provides examples of how GHS label elements can be arranged, while Annex 3 contains the codified hazard and precautionary statements and pictograms.

For consumer products, the UN framework is intentionally flexible. Annex 5 addresses consumer product labeling based on the likelihood of injury and recognizes that competent authorities may apply risk-based approaches in appropriate circumstances. The GHS does not itself create a worldwide consumer-label law or require every consumer product to carry the same GHS elements. Consumer chemicals can instead be subject to national product-safety, pesticide, biocide, cosmetics, household chemical, packaging, or sector-specific rules. Companies should therefore treat the GHS as a harmonized technical reference and verify the legally required consumer label in each country where the product will be sold.

Workplace Label Requirements

Hazard communication in the workplace is one of the principal applications of the GHS. Where a competent authority adopts the GHS for workplace chemicals, labels commonly use the GHS classification and communication system: product identifier, applicable pictograms, signal word, hazard statements, precautionary statements, and supplier identification. The corresponding SDS provides more detailed information for workers, employers, emergency responders, and occupational health professionals.

There is no single UN-enforced workplace label, mandatory language, label size, or implementation deadline that applies worldwide. The GHS uses a modular or “building block” approach, allowing competent authorities to select sectors, hazard classes and categories, implementation instruments, and GHS revisions. This explains why national systems can all be described as GHS-based while differing in classification cut-offs, adopted hazard categories, supplemental statements, language rules, transition periods, and workplace-label provisions. For international supply, the destination jurisdiction’s legislation must always be checked in addition to the UN GHS.

Relationship to Transport Regulations

The UN GHS should also be distinguished from the United Nations Recommendations on the Transport of Dangerous Goods – Model Regulations. The GHS addresses hazard classification and communication across chemical sectors, while the UN Model Regulations provide the international model framework for dangerous-goods transport. The systems are coordinated, particularly for physical hazards and transport pictograms, but transport classification, marks, labels, documentation, packaging, and modal requirements must be assessed separately under the applicable transport rules.

Official Regulatory Resources

• UNECE – About the GHS
• UNECE – GHS Revision 11 (2025)
• UNECE – GHS implementation by region/country
• UNECE – GHS implementation information