GHS label requirements in 2026 under OSHA, EU CLP and GB CLP
GHS label requirements: the six label elements OSHA requires on shipped containers, workplace and secondary container rules, and what EU and GB CLP add.
GHS label requirements
GHS label requirements for a shipped hazardous chemical are six elements under OSHA: product identifier, signal word, hazard statements, pictograms, precautionary statements, and the name, US address and US phone of the manufacturer, importer or other responsible party. GHS is a UN model, not the law: the US rule is 29 CFR 1910.1200(f), while EU CLP and GB CLP add nominal quantity on consumer packs and a supplemental information section where it applies.
The latest UN text is Revision 11 (2025). A GHS compliant label has to meet OSHA HCS, EU CLP or GB CLP.
The six label elements under OSHA
These are the US GHS labeling requirements in paragraph (f)(1). Classification decides which signal word, statements and pictograms apply:
| Element | What OSHA requires |
|---|---|
| Product identifier | Name or number of the chemical |
| Signal word | "Danger" or "Warning" |
| Hazard statements | The statement for each hazard class and category |
| Pictograms | Red diamond frame, black symbol, white background |
| Precautionary statements | Measures to prevent or reduce harm |
| Supplier details | Name, US address and US phone of the manufacturer, importer or other responsible party |
Under paragraph (f), the signal word, hazard statements and pictograms must sit together. English is required, and other languages may be added. Hazards not otherwise classified can stay off the label.
Appendix C sets the pictogram as a black symbol on a white background, inside a red square frame set on a point, and a blank red frame is not allowed. If "Danger" is used, "Warning" must not appear. The skull and crossbones replaces the exclamation mark for acute toxicity, and corrosion replaces it for skin or eye irritation. Where the health hazard symbol is used for respiratory sensitisation, it replaces the exclamation mark for skin sensitisation or for skin or eye irritation.
The environment pictogram is optional. OSHA's QuickCard calls it "Environment (non-mandatory)". CLP requires that diamond where the classification calls for it, so a US label can be short one symbol in Europe.
Small containers and label updates
(f)(12), added in 2024, applies only when a full pull-out label, fold-back label or tag is shown not to be feasible. At 100 ml or less, keep the product identifier, pictograms, signal word, manufacturer name and phone, and a statement that the full label is on the immediate outer package. At 3 ml or less, omit the label only if any label would interfere with normal use, and still show the product identifier on the container. For both sizes, the immediate outer package carries the full label and must say the small containers are stored in that package when not in use.
Under (f)(11), revise the label within six months of significant new hazard information. Containers already released for shipment (packaged and labeled for distribution) need not be relabeled. The updated label must still travel with each container in each shipment.
Secondary container labels
OSHA's workplace labels are what sites call secondary, internal or in-house labels. (f)(6) gives two options. Use shipped-label elements (i) to (v), and leave off the supplier block. Or use the product identifier plus words, pictures or symbols for the general hazards, if other information the employee can get immediately supplies the specific hazards.
Stationary process containers may use signs, placards, batch tickets, process sheets or operating procedures instead, under (f)(7). They must identify the containers, carry the label information, and stay readily accessible in the work area through each shift.
(f)(8) is narrower than many sites assume. No label is needed only when the employee who transferred the chemical from a labeled container will use it immediately. A spray bottle filled on Monday and left for the night shift needs a label.
Don't strip the supplier label off an incoming drum: under (f)(9), remove or deface it only if you immediately mark the required information.
OSHA compliance dates for the 2024 update
The update took effect on 19 July 2024. Paragraph (j)(4) lets you follow the new rule, the old one, or both, during the transition. A final rule of 15 January 2026 moved every date back four months:
| Who | Deadline in (j) |
|---|---|
| Substances: manufacturers, importers, distributors | 19 May 2026 (passed) |
| Substances: employers, as necessary | 20 November 2026 |
| Mixtures: manufacturers, importers, distributors | 19 November 2027 |
| Mixtures: employers, as necessary | 19 May 2028 |
For substances, 20 November 2026 means updates, as necessary, to alternative workplace labels under (f)(6), the hazard communication program, and extra training for newly identified hazards. It is not an order to relabel every bottle on site. That deadline is less than four weeks away.
What EU CLP labelling adds
Article 17 of Regulation (EC) No 1272/2008 lists eight elements. Two are not in the OSHA six: nominal quantity on packs sold to the public, unless already shown on the pack, and a supplemental information section where applicable. Use the official language of each Member State where the product is placed on the market. Extra languages are allowed if each carries the same details.
The supplemental section holds EUH statements, including EUH201 to EUH208 for certain mixtures. Article 25(7) also puts a UFI created under Annex VIII there, unless Annex VIII allows another placement. Do not print "non-toxic", "non-harmful" or "ecological" on the label or the packaging. Article 28(3) caps precautionary statements at six, unless the hazards need more. Article 20(3) bars "Warning" when "Danger" is used.
Font sizes postponed to 2028
Regulation (EU) 2024/2865 set a minimum x-height, the height of the letter x, plus black-on-white text, line spacing and a sans-serif font. Regulation (EU) 2025/2439 moved those formatting rules to 1 January 2028. You may apply them sooner. Further CLP simplification is still under negotiation, so check EUR-Lex before a redesign.
| Pack volume | Minimum x-height |
|---|---|
| Up to 0.5 L | 1.2 mm |
| Over 0.5 L to 3 L | 1.4 mm |
| Over 3 L to 50 L | 1.8 mm |
| Over 50 L | 2.0 mm |
Since 1 July 2026, the consolidated CLP text allows a fold-out label on any pack, and a data carrier linking to a digital label. The label must also name a supplier established in the Union.
GB CLP and Northern Ireland
Great Britain uses assimilated Regulation 1272/2008 (GB CLP). Northern Ireland follows EU CLP (HSE). Article 17 requires English and the supplier's name, address and telephone number. For the other elements, check GB CLP Article 17 itself.
HSE's change list, updated 8 October 2026, shows no new font-size rules. GB CLP has no digital-label provision and no refill-station rules from that 2024 EU revision. HSE still describes nine pictograms, environment included, and usually no more than six precautionary statements.
Workplace containers in the EU and GB
CLP covers labelling before a product is placed on the market. It does not cover a jug you fill on your own site. Directive 98/24/EC Article 8(2) says the contents, their nature and their hazards must be clearly identifiable. COSHH regulation 12(5) requires the same in GB, and HSE's ACOP L5 reads that as the substance name, its form and its hazards. Where a mark is not practical, a procedure can identify the contents.
GHS label example layout
One workable order, not a required template. It shows where each element goes, not which statements a given chemical needs:
- top: product identifier
- middle: pictograms beside the signal word and hazard statements, grouped as OSHA requires
- below: precautionary statements
- bottom: supplier name, address and phone
- EU and GB consumer packs: nominal quantity, unless shown elsewhere, plus supplemental information where required
- EU: the UFI, where Annex VIII applies
Section 2 of the SDS names the classes and categories. Those pick the pictograms and statements. OSHA's brief on labels and pictograms is further US reading.
RegAffairs AI's cited answer on what a GHS label must carry quotes the OSHA and CLP text.