What Global GHS Adoption Means for Chemical Companies Entering New Markets

The Globally Harmonized System of Classification and Labeling of Chemicals was designed to do something straightforward: give every country a common framework for communicating chemical hazards through labels and safety data sheets.

Two decades after its adoption by the United Nations in 2002, that goal has been substantially, though not uniformly, achieved. More countries are formalizing GHS-based requirements than at any point in the system’s history, and the pace of adoption in emerging markets appears to be accelerating.

For chemical manufacturers and distributors looking to expand into new geographies, that trajectory creates documentation obligations that may not be immediately obvious. Purpose-built SDS creation software has become increasingly relevant to organizations managing those obligations across multiple markets simultaneously, though understanding why requires looking at how GHS adoption actually works in practice.

How GHS Adoption Creates Uneven Documentation Terrain

The GHS is a non-binding United Nations framework. According to UNECE, which maintains the system, countries are encouraged to adopt GHS as the basis for their national chemical hazard communication requirements, but each country implements it through its own legislation and on its own timeline.

The result is that while the underlying framework is shared, the specific version adopted, the hazard categories included, the language requirements, and the SDS formatting rules vary from jurisdiction to jurisdiction.

As of 2025, UNECE published GHS Revision 11, the most current edition of the system, incorporating updated classification criteria for aerosols and chemicals under pressure, new guidance for skin-sensitization classification, and new provisions for substances that are hazardous by contributing to global warming.

Countries adopting GHS for the first time or updating existing frameworks are not necessarily aligning with the same revision, and those that adopted earlier versions are not required to update simultaneously.

That fragmentation has practical consequences. A chemical product entering a market that has just enacted GHS-aligned requirements may need a safety data sheet that reflects classification criteria the manufacturer has not previously needed to apply. If the product is already documented for other markets, a direct translation of an existing SDS is unlikely to satisfy the new jurisdiction’s requirements without substantive review and revision.

The Emerging Market Adoption Wave

Several regions that previously lacked formalized GHS-based hazard communication requirements have moved to establish such requirements in the past two years.

• Ukraine enacted the UA-CLP Regulation in November 2024, aligning its chemical classification and labeling requirements with the EU’s CLP framework.
• Vietnam updated its chemicals law in January 2026 through Circular No. 01/2026/TT-BCT, introducing revised SDS requirements for chemical products distributed in that market.
• South Africa has been transitioning from a GHS Revision 4 baseline to a Revision 7 baseline, with full transition timelines running through 2025 and 2026.
• Latin American markets, including Peru, Argentina, and Colombia, are in various stages of finalizing or updating their GHS adoption frameworks.

For chemical companies already holding product registrations and SDS libraries for established markets, each of these developments represents a new documentation obligation. The SDS that satisfies OSHA HazCom, the EU’s CLP regulation, or South Korea’s K-REACH does not automatically satisfy a newly enacted GHS framework in a different jurisdiction, even when those frameworks share a common GHS foundation.

The classification criteria, building blocks, language requirements, and SDS formatting rules each country adopts are its own.

The Revision Lag Problem

One of the more operationally challenging aspects of the current GHS landscape is what might be called revision lag. Different countries have adopted different GHS revisions, and these revisions are not fully harmonized.

Some ASEAN member states currently operate under GHS Revision 3 or 4. The EU’s CLP regulation aligns with GHS Revision 7 in many areas. OSHA’s updated HazCom Standard, amended in 2024, also aligns with GHS Revision 7. Japan and South Korea have selectively adopted elements of later revisions.

The practical consequence is that a single chemical product may require different hazard classifications depending on which country’s GHS implementation applies. A substance that falls below a classification threshold under one revision’s criteria may exceed it under another’s.

An SDS authored to satisfy one jurisdiction’s requirements may not reflect the classification outcome that a different jurisdiction’s criteria would produce for the same product.

For organizations managing SDS libraries across multiple markets, that divergence adds a layer of complexity to every new market entry. The question is not simply whether an SDS exists for a product, but whether the classification underlying that SDS is correct under the specific criteria of each market where the product is sold.

What This Means for Documentation Processes

The documentation implications of expanding GHS adoption are most pronounced for organizations entering markets where they have not previously operated.

Building a compliant SDS for a new jurisdiction requires understanding which GHS revision that jurisdiction has adopted, which building blocks it has included, what language and formatting requirements apply, and whether any jurisdiction-specific additions sit on top of the base GHS framework.

SDS creation software that maintains regulatory content across multiple jurisdictions may reduce the manual research burden associated with each new market entry, though the depth of that coverage varies across platforms.

For organizations considering expansion into markets where GHS requirements are newly enacted or recently updated, verifying that any platform under consideration includes current regulatory content for those specific jurisdictions is worth doing early in the evaluation process.

The broader pattern seems likely to continue. As more countries formalize chemical hazard communication requirements aligned with the GHS, the documentation obligations for chemical manufacturers and distributors operating internationally will continue to expand.

Organizations that have built documentation processes capable of handling that complexity may find new market entries more straightforward than those that approach SDS authoring as a domestic compliance exercise.

Closing Thoughts

The GHS was designed to make chemical hazard communication simpler and more consistent across borders. In many respects, it has, but the variation in how countries implement it means that entering a new market still requires understanding that jurisdiction’s specific requirements rather than assuming a common framework produces common documentation.

For chemical companies tracking expansion opportunities in emerging markets, the documentation question is worth addressing alongside the commercial and regulatory ones.