News Brief
The 11th Revised Edition of the Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS Rev.11) was officially released on September 12, 2025, following amendments adopted by the Transport of Dangerous Goods (TDG) and GHS Expert Committee in December 2024.
This update introduces significant changes aimed at improving chemical classification, labelling, and hazard assessment, with a focus on atmospheric hazards, skin sensitization, and pressurized chemicals.
These revisions are aligned with global chemical management trends and are expected to impact various stages of chemical production, transportation, storage, and sales. Below, REACH24H summarizes the key updates to help enterprises navigate the changes effectively.
Updates to Definitions and Concepts for Accurate Identification
Ozone Depleting Potential (ODP)
The abbreviation "ODP" has been replaced with the full term "Ozone Depleting Potential" to enhance clarity and prevent misunderstandings. The Chinese expression remains unchanged.
Introduction of "Global Warming Potential"
The term "Global Warming Potential" has been officially added to the GHS framework. It is defined as a metric for measuring the heat-trapping capacity of a substance or mixture relative to carbon dioxide, considering cumulative radiative forcing effects over a specific time frame. This addition provides a standardized approach for assessing the climate impact of chemicals, urging enterprises to factor this parameter into product classification and labelling.
Updates to Standards and Guidelines for Clearer Boundaries
Aerosols and Pressurized Chemicals
Aerosols:
Newly defined to exclude classification as pressurized chemicals, flammable gases, compressed gases, flammable liquids, or flammable solids.
Aerosols containing flammable components > 1% by mass or with a heat of combustion ≥ 20 kJ/g must be classified as Aerosol Category 1 unless tested otherwise.
Transportation-related provisions are detailed in Special Provision 63 of the UN Model Regulations.
In order to ensure the consistency of classification rules, the footnotes of the classification rules for flammable gases, flammable liquids and flammable solids will be uniformly changed from "aerosols" to "aerosols and pressurized chemicals".
Pressurized Chemicals:
Defined separately from aerosols, compressed gases, flammable gases, flammable solids, or flammable liquids.
Transportation provisions are outlined in Special Provision 362 of the UN Model Regulations.
Skin Sensitization Guidelines:
Classification Process Optimization:
A tiered approach is prioritized for data evaluation, followed by the bridging principle or component data if necessary. Competent authorities may determine acceptable testing methods, enhancing scientific rigor and flexibility.
Background Guidance and Framework Restructuring:
Two new chapters, "Guidance on Substances – Skin Sensitization" and "Guidance on Mixtures – Skin Sensitization," have been added. Four new assessment methods for mixtures include human data, standard animal data, defined approaches, and non-standalone chemical/in vitro methods.
Atmospheric System Hazards:
The category "Hazardous to the Ozone Layer" has been expanded to "Hazardous to the Atmospheric System," introducing a new subcategory, "Contributing to Global Warming." Classification standards reference the Montreal Protocol annexes, with guidance provided for component concentrations ≥ 0.1%.
Enhanced Measures for Prevention: Annex Revisions
Acute Toxicity:
New precautionary statements P322 ("Immediate specific treatment required, see Safety Data Sheet") and P323 ("Specific treatment, see Safety Data Sheet") have been added.
Atmospheric System Hazards:
A new precautionary statement matrix for "Contributing to Global Warming" has been introduced, with disposal guidance emphasizing recycling information (P502).
Label Updates under GHS Revision 11
Seven label samples have been replaced, clarifying requirements for combination packaging and single packaging. Rules for distinguishing between transport and GHS labels have been added to avoid confusion.
Updates: Guidance on Simple Asphyxiant Gases
Definition: Gases that reduce oxygen levels in the air, causing hypoxia. Examples include CO₂, nitrogen, and methane.
Labelling Rules: Unclassified substances must include hazard warnings in labels and SDS Section 2, such as "May displace oxygen and be fatal.
Compliance Strategy Recommendations for Enterprises
To adapt to the changes in GHS Revision 11, chemical enterprises should:
Update Data: Review and update internal data inventories, including ozone depleting and global warming potentials.
Revise Labels and SDSs: Ensure compliance with new label elements and precautionary statements, particularly for new hazard categories like "Contributing to Global Warming."
Train Employees: Provide training on the revisions to improve compliance in daily operations.
Collaborate with Supply Chains: Share regulatory updates with partners to ensure compliance across the supply chain.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
