January 25, 2017
Whilst many nations across the globe are now beginning to acknowledge and implement the Globally Harmonised System (GHS) for their chemical hazard labelling requirements, you should be aware that in some countries local consumer labelling regulations may still take precedence. This can cause difficulties when producing multi-market labels, as in some cases the information required under one country’s consumer regulations may not be compatible with the labelling requirements for other countries.
Consumer Product Regulations
Where GHS has been adopted as the main standard for chemical legislation, it is almost universally used to provide labelling for industrial and professional products. However, when it comes to consumer products this is not the case, and some countries still favour their original consumer regulations over the standards outlined in GHS.
- United States: US Consumer Product Safety Commission (CPSC)
- Canada: Consumer Chemicals and Containers Regulations, 2001 (CCCR)
- Australia: Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP)
In each of these examples, when it comes to product labelling, the national consumer regulations take precedence over GHS.
Labelling Requirements at a Glance:
|Regulation||GHS||16 CFR Parts 1000-1799 (Which is regulated by the CPSC)||CCCR||SUSMP|
|Criteria||27 hazard categories||5 major hazard categories (with exceptions)||5 major hazard categories||10 Schedules which classify drugs and poisons|
||No Pictogram required|
|Pictogram Size Requirements||No, although many countries have implemented some requirements||No||Yes||No|
|Text Size Requirements||No||Yes||Yes||Yes|
The table above demonstrates some of the fundamental differences between the chemical labelling standards outlined in GHS and in national consumer legislation in the United States, Canada and Australia. These domestic regulations differ from GHS in a number of areas:
- GHS: There are 27 different hazard categories, each with their own labelling requirements.
- United States: There are 5 main hazard categories: If a product contains substances which are toxic, corrosive/irritant, strong sensitisers, flammable/combustible, or which generate pressure through decomposition, heat or other means, they are considered hazardous and are subject to CPSC’s labelling requirements. A few exemptions apply, such as pesticides regulated under FIFRA and food, drugs and cosmetics regulated by the FDA.
- Canada: Under CCCR, any mixture that meets the criteria for toxicity, corrosivity/irritancy, flammability, quick bonding adhesives or pressurised containers has specific labelling requirements.
- Australia: The labelling requirements are based on a list of chemicals which are organised into Schedules 2-10 of SUSMP. Any mixture containing these ingredients at the requisite levels must be labelled in accordance with SUSMP.
- GHS: The 9 main hazard pictograms included within GHS are used for the labelling of containers and for workplace hazard warnings, and appear as black symbols inside a red diamond shaped border (pictured below):
- United States: In general, pictograms are not required under CPSC. However, there are exemptions for particularly poisonous products, and in these instances a skull and crossbones symbol (pictured) shall be applied when appropriate.
- Canada: Under CCCR, hazardous chemical substances are labelled with black bordered hexagonal or triangular pictograms as appropriate. A few examples are pictured below:
Flammable Toxic Corrosive Explosive
- Australia: Under SUSMP there are no pictogram requirements when labelling hazardous substances.
Size and Layout Requirements
- GHS: Whilst GHS has no size or format requirements, many individual countries have implemented their own standards.
- United States: There are size requirements for both the hazard display panel and the text. Certain information must be displayed on the front of the product in the main display panel, whilst the rest can be printed elsewhere on the product. The table below shows the sizing requirements for a 1 litre plastic bottle as specified by CPSC:
|Container||Container Type||Principle Panel Area||Signal word height (Capital letter)||Statement of Hazard (Min. height of capital)||Remaining precautionary texts (Min. height of capital)|
|1L||Plastic Bottle||15 in2||7/64 inch||3/32 inch||1/16 inch|
- Canada: There are minimum size requirements for both the hazard symbol and the text. Additionally, all hazard text must appear in both French and English, and the phrasing used is mandated, including its order and format. The table below shows the sizing requirements for a 1 litre plastic bottle under CCCR:
|Container||Container Type||Principle Panel Area||Symbol minimum diameter||Signal word height||Text (Min. height of capital and point size)||First Aid Information (Min. height of capital and point size)|
|1L||Plastic Bottle||97 cm2||19.2 mm||4.8 mm||3 mm, 6pt||2 mm, 6pt|
- Australia: The text has a mandated size and order, and the phrasing used is mandated. The table below shows the sizing requirements for a 1 litre plastic bottle under SUSMP:
|Container||Container Type||Text (Min. height of capital and point size)||Signal word height||“Keep out of reach of children” height|
|1L||Plastic Bottle||1.5 mm||At least ½ the height of the largest letter on the label or a maximum of 6mm||4/10 of the height of the Signal word|
As you can see, when it comes to labelling consumer products the requirements are not always clear. If you or your company are involved with consumer products, it is crucial that you are aware of the local consumer labelling regulations, as they may take precedence over GHS.
At UL we have a dedicated team of in-house chemical regulatory experts who have a comprehensive understanding of chemical regulations across the globe, and are constantly monitoring these regulations to help hundreds of companies in the chemical sector comply with the complex and ever-evolving chemical legislation.