GHS

How Shall You Label Chemicals Not Classified as Hazardous Under GHS?

Little Pro on 2018-07-09

GHS labels are only required for chemical substances or mixtures classified as hazardous under GHS. This rule applies to a majority of countries that have adopted GHS in chemical hazard communication system. However, from marketing and/or logistical aspects it may in certain cases be useful for suppliers to label all substances and mixtures, including those for which there is no legal obligation to provide GHS labels. In this article, we will share with you the best practice for labelling chemicals not classified as hazardous under GHS.

Practice 1: Keep Product Name and Supplier Identification Info

The core elements of a GHS label include product identifier, supplier identification info, signal word, pictogram, hazard statements and precautionary statements. If your substance or mixture is not classified hazardous under GHS, then there is no need to provide signal word, pictogram, hazard statements and precautionary statements. It is a good practice to keep product name and supplier identification info on product labels to show workers and operators what is inside a container and who the supplier is.

To protect confidential business info, there is no need to indicate ingredient names, substance identifiers and exact concentration or concentration range for each substance.

Practice 2: Indicate That Your Product Is Not Classified as Hazardous

It is desirable to indicate on your product label that your product is not classified as hazardous under GHS and thus does not legally require a GHS label to avoid unnecessary compliance and conformity issues arising. You can include an extra sentence such as “Not classified as hazardous according to GHS” on your label. This sentence is better than “Not hazardous” since a substance or mixture that is not classified under GHS can still cause hazards.

Practice 3: Indicate Obligatory Supplementary Info

Even for a substance or a mixture not classified hazardous, you need to indicate additional obligatory supplementary info. Those supplementary info is usually country-specific and depends on sector. For example, EU CLP regulation (EU GHS) article 25(6) requires the labelling of the following supplementary info even when a mixture is not classified hazardous.

Type

Extra labelling Info

Products supplied to the general public

Nominal quantity

For mixtures not classified as hazardous under CLP and not intended for the general public but which contain certain specified classified components at above specified limits, for which an SDS must be provided on request

EUH 210 ‘Safety data sheet available on request’

Mixtures not classified as sensitising but containing at least one sensitising substance

EUH208 ‘Contains (name of sensitising substance). May produce an allergic reaction’

Mixture containing ingredient(s) of unknown acute toxicity at a concentration at 1% or greater

‘x percent of the mixture consists of component(s) of unknown acute toxicity’ (also for safety data sheet)

Mixture where no useable information on the short-term (acute) and/or long-term (chronic) aquatic hazard is available for one or more of the relevant components

‘Contains x percent of components with unknown hazards to the aquatic environment’

For decorative paints and varnishes containing VOCs.

Indicate the legal limit value for VOC contents and the maximum content of VOC of the product in ready use conditions.

Reference

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 Tags: Topics - GHSGHS SDS and Labelling