GHS Label Requirements

Yes, in general. When you decant a hazardous chemical into a secondary (transfer) container at work, that container must be labelled or otherwise identified. The usual exception is a portable container whose contents are used straight away by the person who filled it. The rule comes from workplace health and safety law, not supply law. EU CLP covers labelling "before placing on the market" (Art. 4(4)) ^[9], so in-house containers fall under the employer's duties.

Jurisdiction	Duty for secondary containers	What the label must show	Exemption
US (OSHA HCS, 29 CFR 1910.1200(f)(6); OSHA directive CPL 02-02-079, effective 19 May 2026)	Workplace labels, which OSHA says are "sometimes called secondary, internal or in-house labels" [10]	Either the full shipped-container label elements, or the product identifier plus general hazard information (words, pictures or symbols). Symbols must not contradict the GHS pictograms. Employers must update workplace labels for classification changes by 20 Nov 2026 (substances) and 19 May 2028 (mixtures)	Portable containers filled from a labelled container and meant only for the immediate use of the employee who did the transfer [11]
Canada (federal workplaces, COHSR Part X)	An employer who moves a hazardous product into a container other than the supplier's must label it (s. 10.35(2)) [12]	Product identifier, hazard information, and a statement that the SDS is available in the workplace	Portable container filled from a labelled container (s. 10.37), if either (a) the product is for immediate use, or (b) it stays under the control of the employee who filled it, is used only during that shift, and carries a workplace label showing the product identifier (Justice Laws) [13]
EU (Chemical Agents Directive 98/24/EC, Art. 8(2))	Where containers and pipes are not marked under EU labelling or safety-sign law, the employer must make sure their contents, the nature of those contents and any hazards are clearly identifiable [14]	No set format; the contents and hazards must be "clearly identifiable"	Only the derogations in the labelling and safety-sign legislation
Ireland (S.I. 619/2001, Reg. 9(3))	All containers and pipes used at work for hazardous chemical agents must be clearly labelled or identified as to their contents and hazards [15]	Contents and associated hazards	None stated
GB (COSHH 2002, Reg. 12(5))	Same wording as the EU directive: where containers and pipes are not marked under the legislation listed in Schedule 7, their contents and hazards must be clearly identifiable [16]	HSE's ACOP L5 lists the substance name(s), its form (liquid, powder, etc.) and the hazards [17]	HSE says the rule covers cases where no other law requires marking, and notes that many containers are already marked for supply [18]. Where marking isn't practical, a procedure can identify the contents instead (e.g. operating instructions, plant numbering) [19]
Australia (model WHS Regulations; Safe Work Australia Code of Practice)	A business must make sure chemicals decanted or transferred from the original container are correctly labelled [20]	If not used immediately or supplied to someone else: in English, with at least the product identifier and a hazard pictogram or hazard statement [21]	The entire amount is used immediately: never left unattended, used only by someone present at the decanting, and the container cleaned straight after [22]
Brazil (NR-26, consolidated 2022)	Chemicals used at work must be classified under GHS [23]. The label is defined as attached to "the packaging that contains the product" [24]	GHS elements for hazardous products [25]	NR-26 has no specific provision on transfer containers

Points that catch people out

• "Immediate use" is narrow. In Safe Work Australia's example, solvent left over at the end of a shift for a second worker no longer counts as immediate use ^[22]. Canada's alternative exemption ends at the end of the shift and still requires the product identifier on the container ^[13].
• Reusable decanting containers: Safe Work Australia says a container used repeatedly for decanting should carry a permanent label and must not be used for anything else ^[22].
• Repacking for supply is not decanting. Rebottling for another workplace counts as supply in Australia, and full supplier labelling applies ^[21]. A US pesticide moved into a secondary container must also meet EPA/FIFRA rules ^[26].
• Lost or illegible labels (Canada): the employer must replace them with a workplace label and keep that label up to date with new hazard information ^[27].
• Pipework: the EU, Irish and GB rules cover pipes as well as containers. Australia requires pipework to be identified so far as reasonably practicable ^[20].

The EU entry above is the original 1998 text of Article 8(2). Canada's provinces have their own WHMIS workplace rules, which I didn't cover here.

Approach: I searched the OSHA HCS inspection directive, Canada's COHSR (confirming s. 10.37 on Justice Laws), the EU Chemical Agents Directive and EU CLP, Ireland's Chemical Agents Regulations, GB COSHH with HSE's ACOP L5, Safe Work Australia's Codes of Practice and Brazil's NR-26. The Mexican NOM-018-STPS-2015 records I can search hold only its hazard tables, so I found nothing there on transfer containers.

Sources:

• Canada Occupational Health and Safety Regulations, SOR/86-304, s. 10.37 (Justice Laws)

For a container you fill and use in-house, CLP makes no difference between the EU and GB. Neither regulation applies, because both cover labelling only "before placing it on the market" (Art. 4(4)). Your duties for workplace decanting come from the EU Chemical Agents Directive (and each Member State's law that implements it) or from GB COSHH Reg. 12(5), as in my last answer. CLP comes in when the "secondary" container is supplied to someone else, or is the inner part of a supplied package. In those cases the EU and GB texts start to differ, mainly because of the EU's 2024 amendment, Regulation (EU) 2024/2865.

Why in-house decanting falls outside CLP

• Both texts tie labelling to supply: "suppliers shall ensure that the substance or mixture is labelled and packaged… before placing it on the market" ^[9][28].
• GB CLP defines "placing on the market" as supplying or making available to a third party. It defines "use" to include "filling into containers, transfer from one container to another" ^[29]. Decanting is therefore a use, not a supply. I printed these definitions only from the GB text, not the EU one.
• If you rebottle and pass the product on to anyone else, you become a supplier. The full CLP label then applies in either jurisdiction.

Where the two texts are the same

Rule	EU CLP	GB CLP
Outer, inner and intermediate packaging (Art. 33): inner packaging must carry a CLP label; the outer can skip CLP pictograms that duplicate transport ones, or skip labelling if the inner label is visible through it	[30]	Identical wording [31]
Label fixed to the packaging that immediately contains the product; label elements clear and indelible (Art. 31(1)-(5))	[32]	[33]
Small or awkward packs (Art. 29(1)-(2)): label elements may go on fold-out labels, tie-on tags or outer packaging (Annex I 1.5.1). The inner pack then needs at least the pictograms, the product identifier and the supplier's name and phone number	[34]	[35][36]
Inner packs of 10 ml or less supplied for R&D or QC analysis: label elements may be left off the inner pack if the outer pack is fully labelled (Annex I 1.5.2.4)	Referenced in Art. 61(7) [37]	[36]
Packaging strength and child-safety requirements (Art. 35(1)-(3))	[38]	[39]

Where they differ

Point	EU CLP (consolidated text of 1 July 2026)	GB CLP
Refill stations (the closest CLP gets to a customer filling their own container)	New Art. 35(2a): hazardous products may be sold to consumers and professional users through refill stations only under Annex II section 3.4 [38]. The station must carry the product's label, every refilled pack must meet the full Title III labelling and Title IV packaging rules, and refill is banned for many classes. These include any acute toxicity, Skin Corr. 1, Eye Dam. 1, any sensitisation, CMR, aspiration hazard, flammable liquids Cat. 1-2, and ED, PBT/vPvB and PMT/vPvM [40][41]. "Refill" and "refill station" are now defined terms [42]	Art. 35 has no refill paragraph [39], and I found no refill provision anywhere in GB CLP
Fuel pumped into portable receptacles	Label elements must be shown on the pump, and a physical copy must be provided to attach to the receptacle (Annex II Part 5) [41]	Art. 29(3) only requires unpackaged Part 5 products supplied to the public to come with a copy of the label elements [35]
Fold-out and digital labels	Art. 31(1), (1a) and (1b) now allow fold-out labels on any pack, and digital labels linked by a data carrier [32]	Fold-out labels only under the small-pack exemption; Art. 31 has no digital-label provision [33][36]
Who must be on the label	A supplier established in the Union must be identified on the label (Art. 4(11)) [9]	Art. 4 has no equivalent paragraph. Distributors and downstream users relying on someone else's classification must be established in Great Britain (Art. 4(5)-(6)) [28]
Transition	Packs placed on the market before 1 July 2026 that complied with the old Art. 29 and Annex I 1.5.1.2 / 1.5.2.4.1 have until 1 July 2028. Packs placed on the market before 1 January 2027 that complied with the old Art. 31(3) and Annex I 1.2.1 formatting rules have until 1 January 2029 (Art. 61(7)-(8)) [37]	No equivalent change

In practice: a transfer container used on your own site follows the Chemical Agents Directive (and the national law implementing it) in the EU, and COSHH in GB. The minimum is that contents and hazards are clearly identifiable; HSE's ACOP L5 adds name, physical form and hazards in GB. If you refill packs and sell them on, or run a refill point for customers, the EU now has a specific regime with banned hazard classes. GB CLP has no such regime, so a refilled pack in GB is simply a supplied pack that needs a full CLP label. "UK" is also not one regime: GB CLP covers Great Britain and treats goods from Northern Ireland as a separate category ^[43]. I did not check the Northern Ireland rules here.

Approach: I compared the consolidated EU CLP text (1 July 2026, including the Regulation (EU) 2024/2865 amendments) with GB CLP as published on legislation.gov.uk. The workplace rules come from the Chemical Agents Directive and COSHH sources cited in my previous answer.