How Does GHS in the European Union Differ from GHS in the United States?
In its original concept, the GHS (Globally Harmonized System of Classification and Labelling of Chemicals) was intended to address one of the major challenges of the global chemicals market: the lack of consistent rules for hazard classification and communication. In practice, however, GHS is not a single, universally binding legal act. Instead, it is a set of UN recommendations that individual countries and regions implement on their own terms.
As a result, the same chemical product may be subject to different regulatory requirements depending on the market in which it is placed. The European Union and the United States provide a particularly clear illustration of this reality. The differences are visible not only in the legal frameworks themselves, but also in their practical application, including safety data sheets (SDS).
For manufacturers, importers and distributors operating on both markets, this distinction is critical. The incorrect assumption that “GHS is the same everywhere” very often leads to non-compliant documentation and regulatory issues.
GHS as a system of recommendations, not law
A key point to understand is that GHS itself does not apply directly in any country. It is not a legal act, but a system of criteria and rules that must be implemented through national legislation or, in the case of the European Union, through EU law.
In the EU, GHS has been implemented primarily through the CLP Regulation (EC) No 1272/2008 and the REACH Regulation (EC) No 1907/2006. These are binding legal acts that apply directly in all EU Member States. Importantly, CLP and REACH do not merely transpose GHS requirements, but also expand and refine them, making the EU one of the most comprehensively regulated chemical markets in the world. It is worth noting that the EU approach often influences GHS implementation in other regions, such as Türkiye or South Korea.
In the United States, GHS has been incorporated through the Hazard Communication Standard (HCS, OSHA HazCom) issued by OSHA. This standard focuses primarily on worker safety and hazard communication in the workplace, rather than on comprehensive chemical management throughout the entire product lifecycle.
At this level, a fundamental difference in regulatory philosophy becomes apparent:
the EU treats GHS as part of a broader chemicals regulatory system, whereas the US treats it mainly as a workplace hazard communication tool.
Product labelling – professional versus consumer use
This difference in regulatory philosophy has a direct impact on product labelling. While products intended for professional or industrial use are labelled in a broadly similar manner in both jurisdictions, using familiar GHS pictograms, the situation changes significantly when it comes to consumer products.
In the European Union, products intended for consumer use are subject to the CLP Regulation and are labelled in a manner very similar – and often identical – to products used in workplaces or industrial facilities. In the United States, by contrast, consumer products fall under the jurisdiction of the Consumer Product Safety Commission (CPSC). These rules have little in common with GHS or OSHA HazCom. In addition, state-level requirements, such as California Proposition 65, introduce further obligations related to hazard communication.
Differences in the scope of GHS implementation
Although both CLP and OSHA HCS are based on the same UN GHS documents, the scope of their implementation is not identical. The European Union applies GHS in a more comprehensive and detailed manner, introducing additional obligations such as:
- C&L notifications,
- PCN submissions,
- additional hazard classes, including endocrine disruptors,
- highly detailed requirements for the content of safety data sheets.
In the US system, some hazard classes are applied in a simplified form, while certain GHS elements described in UN documents are not implemented under OSHA HCS at all. This applies in particular to areas not directly related to workplace safety, such as environmental protection. In practice, there is no mandatory requirement to classify products for hazards to the aquatic environment. While the use of these hazard classes is permitted, it is not mandatory, which is an important consideration when reviewing SDSs received from US suppliers.
As a result, a substance or mixture classified in accordance with CLP may:
- have a broader hazard classification than its US counterpart,
- require more extensive labelling,
- trigger additional documentation obligations.
Safety data sheets – seemingly similar, fundamentally different
One of the most common mistakes made by companies operating globally is the belief that a single “GHS-compliant” safety data sheet is sufficient for both markets. Formally, SDSs in both the EU and the US consist of 16 sections, but the required content and level of detail differ significantly.
In the European Union, the safety data sheet is closely linked to REACH and CLP. This means that the SDS must include not only hazard information, but also references to regulatory obligations, use restrictions, the regulatory status of substances under EU legislation and, in certain cases, a PBT/vPvB assessment.
In the United States, an SDS prepared in accordance with OSHA HCS is more functional in nature and focused on the end user in the workplace. The scope of regulatory information is narrower, and references to federal and state legislation are more general. As a result, US SDSs are often considerably shorter and less detailed than their EU counterparts.
The differences are particularly visible in:
- Section 2, where discrepancies in classification between jurisdictions are common;
- Section 3, where EU legislation requires disclosure of component classification, while US SDSs widely rely on trade secret claims and do not require classification of individual components;
- Section 15, which in the EU directly refers to REACH, CLP and other EU legislation, while in the US it has a more general character;
- toxicological and ecological sections, which are typically far more detailed in EU SDSs.
Hazard statements (H-phrases) and precautionary statements (P-phrases)
Both CLP and OSHA HazCom use hazard and precautionary statements derived from GHS. However, their selection and presentation are not always identical. The European Union requires full consistency with the CLP annexes, whereas the US allows certain simplifications, provided that the objective of effective hazard communication in the workplace is met.
What does this mean in practice for companies?
The differences between GHS implementation in the EU and the US are not merely theoretical. They have a direct impact on:
- product classification,
- the scope and content of safety data sheets,
- the responsibilities of manufacturers and importers,
- the risk of documentation being challenged during inspections.
A safety data sheet prepared for the US market should not be automatically used in the European Union. The issue is not limited to language requirements; it primarily concerns differences in classification, the extensive use of trade secret claims and the broader information requirements under REACH. The situation is similar in the opposite direction: an EU SDS, even if prepared in English, will rarely be accepted by a US recipient due to references to EU legislation and differences in format and structure.
Summary
Although GHS was intended to be a globally harmonized system, practical experience shows that local implementation is decisive. The European Union applies a more regulatory and comprehensive approach, while the United States focuses primarily on workplace safety. For companies operating internationally, this leads to a clear conclusion: GHS compliance must always be assessed in the context of the relevant jurisdiction, and safety data sheets must be prepared with local legal requirements in mind, not solely on the basis of global UN guidelines.
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