GHS Implementation by Country: Status, Revisions & Compliance Guide

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a non-binding United Nations initiative. This means each country adopts it into its own national legislation, creating variations in versions, deadlines, and the specific hazard categories (known as “building blocks”) they choose to regulate.

Navigating these country-specific implementations is crucial for chemical manufacturers and suppliers engaging in international trade. Here is a breakdown of the GHS status in several key global markets.

Table of Contents

🌎 Major Economies: GHS Status and Key Variations

1. United States (USA) 🇺🇸

National Regulation: OSHA Hazard Communication Standard (HCS 2012) (29 CFR 1910.1200).

GHS Version: Currently aligned with GHS Revision 3.

Key Status: On May 20, 2024, the Occupational Safety and Health Administration (OSHA) amended the Hazard Communication Standard (HCS) to align with the 7th Revised Edition of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The amendment includes elements from the 8th Revised Edition of the GHS and retains certain U.S.-specific requirements. The regulation takes effect on July 19, 2024. Manufacturers, importers, and distributors shall be in compliance with all modified provisions no later than: substances to January 19, 2026, mixtures to July 19, 2027. For substances, all employers shall, as necessary, update any alternative workplace labelling, update the hazard communication program, and provide any additional employee training for newly identified physical hazard, or health hazards or other hazards covered under this section no later than July 20, 2026. For mixtures, no later than January 19, 2028.

Building Blocks: The US selectively adopted building blocks, notably not regulating environmental hazards under OSHA, and adding certain hazard classes (e.g., combustible dust) not originally in GHS Rev 3.

2. European Union (EU) 🇪🇺

National Regulation: Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures (CLP Regulation).

GHS Version: Aligned through various Adaptations to Technical Progress (ATPs), currently reflecting up to GHS Revision 7 (with earlier revisions still enforced).

Key Status: The EU is a front-runner, often adding new hazard classes ahead of the UN GHS, such as classifications for Endocrine Disruptors (for both health and environment) and PBT/vPvB (Persistent, Bioaccumulative, and Toxic/very Persistent and very Bioaccumulative) substances.

3. Canada 🇨🇦

National Regulation: Workplace Hazardous Materials Information System (WHMIS 2015), governed by the federal Hazardous Products Regulations (HPR).

GHS Version: Currently aligned with GHS Revision 7 (following a regulatory update that took full effect in late 2022/early 2023).

Key Status: Like the US, Canada is a selective adopter, but its implementation (WHMIS 2015) integrated GHS by updating existing national legislation. It includes unique Canadian provisions like a Biohazardous Infectious Materials class (not part of GHS).

4. Australia 🇦🇺

National Regulation: Model Work Health and Safety (WHS) Regulations (managed by Safe Work Australia).

GHS Version: Fully transitioned to GHS Revision 7 as of January 1, 2023.

Key Status: Australia mandated a transition from GHS Rev 3 to Rev 7, meaning only Rev 7 can now be used for classification and labeling in the workplace sector across all states and territories.

5. China (PRC) 🇨🇳

National Regulation: Various national standards (GB standards) and regulations, primarily overseen by the Ministry of Industry and Information Technology (MIIT).

GHS Version: New Mandatory standard GB 30000.1 titled Specification for classification and labelling of chemicals – Part 1: General rules, replaced GB 13690-2009, General rules for classification and hazard communication of chemicals, on 1 August 2025. New standard aligns with GHS Rev 8.

Key Status: China has a very specific national catalog and utilizes a large set of mandatory GHS building blocks, requiring high specificity in both classification and labeling for chemicals entering the country.

6. Japan 🇯🇵

National Regulation: Several laws, including the Industrial Safety and Health Act (ISHA) and the Poisonous and Deleterious Substances Control Act (PDSCA).

GHS Version: Japan’s current GHS regulations are the ‘Chemical Classification’ (JIS Z7252: 2019) and the ‘Hazard Communication of Chemicals—Labels and Safety Data Sheets’ (JIS Z7253: 2019), which are based on the United Nations UN GHS Revision 6.

Key Status: Japan was an early adopter of GHS and enforces the system through multiple pieces of chemical legislation, leading to complexity. Classification is often performed against a government-published priority list.

Other Notable Adoptions and Variances

Region/Country	Implementation Status & Key Feature	GHS Revision Focus
South Korea (Korea)	Mandatory for both substances and mixtures, with detailed sector-specific rules (Environment, Labor).	Revision 4
New Zealand	Early adopter (since 2006) via the HSNO Act, using a unique system of classification codes that aligns with GHS principles. Adopted GHS Rev 7 into the national laws. They had four-year transitional period that ended on 30 April 2025. From this date onwards, all requirements must comply with the new regulations.
Brazil	Brazil has implemented the ABNT NBR 14725:2023 standard, adapted to the 7th revision of the UN GHS. It entered into force on July 3, 2023, with a two-year transitional period ending on July 4, 2025, when all safety data sheets must meet the new requirements. Pure substances and mixtures must be classified according to NBR 14725-2, packed and labelled according to NBR 14725-3, and their SDSs must be authored using NBR 14725-4
Southeast Asia (e.g., Singapore, Malaysia, Thailand)	Varies, generally based on earlier revisions (Rev 3 or 4) and often implemented through industrial standards or ministerial decrees. Singapore implemented GHS Rev 7 on February 6, 2025. This change was announced on February 6, 2023 with two year transition period.

The Compliance Challenge: Why Consistency Isn’t Guaranteed

The UN GHS is often described as a “toolbox,” not a rigid blueprint. This building block approach allows countries to:

Select GHS Revision: Use GHS Rev. 3, Rev. 7, Rev. 9, or any other version.

Select Hazard Classes: Choose which physical, health, and environmental hazards to adopt.

Vary Thresholds: Apply different concentration limits or cutoff values for classifying mixtures.

This means a chemical classified under EU CLP (Rev 7) may require re-classification and different labeling to comply with the US HCS (Rev 3) or Canadian WHMIS (Rev 7), highlighting the ongoing need for expert regulatory monitoring.

Conclusion: Navigating the Global GHS Maze with H2 Compliance

The Globally Harmonized System (GHS) has successfully created a global foundation for chemical hazard communication, replacing countless proprietary national systems. However, the reality of global trade demonstrates that harmonization does not mean uniformity.

As highlighted by the country-specific breakdowns—from the EU’s proactive adoption of new hazard classes to the differing GHS revisions used in the US and Australia—the “building block” approach has created a complex web of requirements.

This is why expert regulatory partnership is non-negotiable.

Ensure Your Products Can Move Freely and Safely

For manufacturers and suppliers, the consequence of non-compliance can be catastrophic: fines, border seizures, and complete disruption of the supply chain. You need to ensure that your Safety Data Sheets (SDSs) and labels are 100% accurate, not just for the US, but for every market you enter, respecting the GHS revision, adopted building blocks, and linguistic requirements of that specific country.

H2 Compliance specializes in deciphering this global regulatory landscape. We provide comprehensive, up-to-date SDS authoring, re-classification, and labeling services tailored to the specific legal frameworks of the US, EU, Canada, China, and dozens of other adopting countries.

Don’t let the nuances of GHS Rev. 3 vs. Rev. 7, or the inclusion of country-specific hazard classes, become a barrier to trade. Partner with us to transform your chemical data into compliant, reliable hazard communication documents worldwide.