GHS Labelling

What is GHS Labelling?

GHS labelling is a system for communicating the hazards of chemical products by using pictograms, signal words, hazard statements, precautionary statements and supplier information.

GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. It is designed to make chemical hazard information easier to understand across countries and industries.

For forwarders, NVOCCs and overseas shipping offices arranging cargo to Japan, GHS labelling is an important warning sign. It may indicate that the cargo is a chemical product with fire, toxicity, corrosive, environmental or other hazards.

However, GHS labelling and dangerous goods classification for international transport are not the same thing. A product with a GHS label is not always regulated as dangerous goods under transport rules, and a product without an obvious GHS label may still be regulated as dangerous goods for sea or air transport.

Overview

GHS is a hazard communication system for chemical substances and mixtures. It classifies hazards such as explosiveness, flammability, acute toxicity, skin corrosion, serious health hazards and environmental hazards, and communicates them through labels and Safety Data Sheets.

In Japan, certain chemical products may be subject to labelling, SDS provision or other information requirements under laws such as chemical management regulations, the Industrial Safety and Health Act, and the Poisonous and Deleterious Substances Control Act.

The scope of obligations differs depending on the substance, mixture, use, concentration and applicable law. Therefore, forwarders should not treat GHS labelling as a simple customs label. It should be used as a trigger to confirm the actual chemical and transport classification.

Main Elements of a GHS Label

A GHS label commonly includes the following elements:

• Product identifier or chemical name
• Hazard pictograms
• Signal word
• Hazard statements
• Precautionary statements
• Supplier identification

These label elements are assigned according to the relevant hazard class and hazard category. For logistics practice, the pictogram alone is not enough. The SDS, product name, composition, transport information and packaging details should also be checked.

Meaning of GHS Pictograms

GHS pictograms are shown inside a red diamond-shaped frame. Typical pictograms include explosives, flame, oxidizer (flame over circle), gas cylinder, corrosion, skull and crossbones, exclamation mark (irritant or harmful), health hazard (serious health effects, respiratory sensitizer, carcinogen and similar hazards), and environmental hazard.

If a forwarder finds GHS pictograms on the product container, inner package, outer package or related documents, the cargo should not be handled casually as ordinary cargo. The latest SDS should be obtained and the transport information section should be checked.

In practice, particular attention is needed for products such as paints, adhesives, cleaning agents, fragrances, inks, laboratory reagents, alcohol-containing products, aerosols and chemical samples. These products are often described commercially as ordinary goods, but may require dangerous goods review for transport.

Difference Between GHS Labelling and Dangerous Goods Transport

GHS labelling is intended to communicate chemical hazards. Dangerous goods transport rules, on the other hand, are intended to control transport risks during sea, air or other modes of transport.

For international transport, forwarders normally need to check rules such as the IMDG Code for sea transport and the IATA Dangerous Goods Regulations for air transport. These rules focus on matters such as UN number, proper shipping name, dangerous goods class, packing group, packaging instructions, labels, marks and dangerous goods declarations.

Therefore, a GHS label does not automatically mean that the cargo is regulated as dangerous goods for transport. Conversely, a cargo may be dangerous goods for transport even if the GHS label is not obvious to the logistics operator.

The correct approach is to compare the GHS label, SDS, transport information, invoice description, packing details and carrier acceptance conditions.

Practical Checkpoints for Forwarders

This section covers the forwarder's own document and cargo checks before booking, warehousing, consolidation or shipment.

• Check whether GHS pictograms or other hazard marks appear on the product, inner package or outer package.
• Obtain the latest SDS from the shipper or manufacturer.
• Confirm whether the SDS product name matches the invoice, packing list and actual cargo.
• Check whether Section 14 of the SDS contains a UN number, dangerous goods class or packing group.
• Confirm whether the cargo is regulated for sea transport, air transport or both.
• Check whether the dangerous goods declaration is consistent with the SDS and actual cargo.
• Confirm whether the warehouse, CFS, shipping line or airline can accept the cargo.

In Japanese logistics practice, a shipper may say, “The product has a GHS label, but it is not dangerous goods.” This explanation may be correct, but it should not be accepted without checking the SDS and, where necessary, the manufacturer's written confirmation or carrier acceptance conditions.

Questions to Ask the Shipper

This section is different from the forwarder's internal checklist. These are practical questions to ask the shipper, manufacturer or overseas supplier when the documents or cargo markings are unclear.

• Is the latest SDS available?
• Does the GHS label match the SDS?
• Is the product regulated as dangerous goods for transport?
• Is there a UN number, dangerous goods class or packing group?
• Are the conditions different for sea transport and air transport?
• Are the product label, outer package marks and transport labels appropriate?
• If the product is non-dangerous goods, is there supporting documentation, such as a statement of non-dangerous goods or non-hazardous goods declaration?

Common Problems

• GHS pictograms appear on the package, but no dangerous goods declaration is provided.
• The SDS says the product is not dangerous goods, but the actual product label shows hazard pictograms.
• The product name on the invoice does not match the SDS.
• An outdated SDS is used for booking or carrier confirmation.
• The cargo is acceptable for sea transport but not acceptable for air transport.
• A warehouse or CFS asks for additional confirmation because hazard marks are visible on the package.

Many of these problems arise because GHS labels, SDS information, dangerous goods declarations and transport labels are treated as if they were the same thing. They are related, but they have different purposes.

Practical Notes for Shipments to Japan

For cargo moving to Japan, overseas forwarders should be especially careful not to rely only on the shipper's commercial description. Japanese importers, customs brokers, warehouses, shipping lines and airlines may ask for additional confirmation when chemical hazard information is unclear.

Japan often operates with a conservative documentation culture. Even if the legal classification appears simple, the practical handling may require a clear SDS, manufacturer confirmation, statement of non-dangerous goods, non-hazardous goods declaration, or prior acceptance from the carrier or warehouse.

For this reason, GHS labelling should be treated as an early warning signal. It does not decide the transport classification by itself, but it tells the forwarder that the cargo requires careful document checking before booking, consolidation, warehousing or shipment.

Key Point

GHS labelling is not the same as dangerous goods classification for transport. For forwarders, the important point is to use the GHS label as a trigger to check the SDS, UN number, dangerous goods class, packing group, transport mode and carrier acceptance conditions.

When there is any doubt, the forwarder should confirm the position with the shipper, manufacturer, shipping line, airline or warehouse before arranging shipment to Japan.