GHS vs. CLP system of classification and labelling of chemicals – do you know what the differences are?

I have already written many times about the classification and labelling of chemicals defined by the chemical regulations.

Today, I will tell you something more about the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (GHS system). This is the system adopted by the United Nations and on which the classification and labelling system in our region is based. 

However, there are differences that can be confusing and about which I have had several enquiries. Let’s therefore first look at what GHS is.

The GHS system of classification and labelling of chemicals is an international standard developed by the United Nations in order to align the approach to classification of chemical hazards at the global level.

It is a global framework which is not binding and from which individual countries can select the parts they will implement (so-called “building blocks” approach). 

By implementing selected parts of GHS into national legislation these provisions become binding. This approach allows countries a certain flexibility in choosing what they consider most relevant, but also leads to variations in how GHS is implemented globally. 

On the other hand, the Regulation (EC) 1272/2008 of the European Union on classification, labelling and packaging of chemicals (the so-called CLP Regulation) is a binding regulation which in a certain measure implements the GHS system in the European Union. Specifically, the chemical classification and labelling regulations in Bosnia and Herzegovina are based on this regulation. 

So when we say that in our region the GHS system of classification and labelling of chemicals is applied, we actually mean the part of that system which has been implemented by the CLP Regulation. 

GHS and CLP define the criteria for classification of chemicals in order to assess hazards in a standardised way. The same basic elements of hazard labelling are established.

However, there are differences which stem from two key reasons:

1. Not all categories within certain hazard classes under GHS have been adopted in the CLP system. 

2. In the EU there are additional hazard classes and labelling rules which are not established under GHS. 

Regarding hazard categorisation within a certain hazard class, the lowest categories for certain classes have not been adopted into the European legislation. It is considered that these categories indicate a negligible level of hazard which can be omitted. Into this group fall the following hazard classes / categories:

• Flammable liquids category 4 (H227) 

• Acute toxicity category 5 (H303, H313, H333)

• Skin irritation category 3 (H316) 

• Eye irritation category 2B (H320)

• Aspiration hazard category 2 (H305)

• Acute hazard to the aquatic environment categories 2 and 3 (H401 and H402) 

If you ever came across these H-codes and they were not familiar to you under local classification and labelling regulations, now you know where they originated. Because their use is not prescribed here, they should be omitted from the safety data sheets (SDS) and labels for our market. 

Let’s now look at the additional hazard classes that are prescribed in the European Union (and thus also apply here) which do not exist in the GHS system:

• Endocrine disruptors for human health categories 1 and 2 – EUH380 and EUH381 

• Endocrine disruptors for the environment categories 1 and 2 – EUH430 and EUH431 

• Persistent, bio-accumulative and toxic properties (PBT) – EUH440 

• Very persistent and very bio-accumulative properties (vPvB) – EUH441 

• Persistent, mobile and toxic properties (PMT) – EUH450

• Very persistent and very mobile properties (vPvM) – EUH451 

The EUH labels – additional hazard statements – may already be familiar to you. Unlike the H-statements (hazard statements) which originate from the GHS system, these labels apply only in the European Union. Of course, they also apply in other countries which apply the CLP system, such as Bosnia and Herzegovina and other Southeastern European countries. 

In the European Union, and also in our region, there are specific requirements regarding the size and format of the label, as well as rules for the application of child-resistant caps and tactile warning of danger. 

All of these are reasons to pay special attention if you have chemical suppliers from outside the European Union (or another area which applies the CLP system), or if you export to other countries. 

If you need help with classification and labelling of chemicals or with preparing safety data sheets (SDS) / labels for our or another market, please get in touch at nina.pajovic@bens-consulting.eu.