GHS/CLP Frequently Asked Questions

A little confused about GHS/CLP? We have some frequently asked questions and their answers. You should still refer to the official website (shown below) for all the details, but this should give you a good start.

Email us at for more information on how our web-based PLM solution, DevEX, can help you prepare:

analyze current formulations (including formula-within-a-formula)
manage vendors and instantly view material specifications throughout development
generate new labeling and compliance documentation

Is the red frame mandatory for GHS pictograms?
Yes, it is. All the pictograms on the label must be full color with a red frame, white background and black picture.

During the transitional period, if I create a SDS for product according both to CLP and existing criteria, which criteria do I have to follow for the labels?
In this case, the label should be in accordance to the new CLP criteria

If my product is already labeled with the existing classification, and it is on sale, should I retire it from the market if it isn’t sold before 1.12.2010 (if it is a substance) or 1.6.2015 (if it is a mixture)?
No, you shouldn’t. In order to dispose the old stocks, you can sell the substances with the existing label until 1.12.2012 (for substances) and 1.6.2017 (for mixtures)

What are the main differences between the ONU GHS and the European implementation of GHS, the Regulation CLP?
The Europe applied the ”building block approach” for the implementation of the regulation CLP from GHS, so Europe decided to not implement some categories of danger, for example: inflammable liquids category 4; acute toxicity category 4. According to building block approach, if a danger category is present both in GHS and CLP, it is characterized by same pictograms, hazard statements and precautionary statements.

Does GHS harmonize the transport legislation? Does it replace ADR in Europe or DOT in USA?
No, it doesn’t. The transport legislation is still valid, even if there are some analogies between GHS and ADR and DOT. In fact the GHS Purple book and Orange books (from which ADR derives) are written by the same ONU Commission. There are a lot of similarities between GHS physical hazard and ADR classes.

You may find out more specifics about GHS/CLP regulation at the official website:

http://ec.europa.eu/enterprise/reach/ghs/index_en.htm