The EU operates under CLP Regulation — its own implementation of GHS — while the US is mid-transition to OSHA HazCom 2024, based on GHS Revision 7. Japanese SDSs aligned to JIS Z 7253:2019 diverge from both in ways that go beyond wording: classification criteria differ, mandatory fields are missing, and some sections require a full rewrite rather than any form of translation.
Comparison of Requirements Across Three Regions
| Region | Standard | Language | GHS Base | Key Characteristics |
|---|---|---|---|---|
| Japan | JIS Z 7253:2019 | Japanese | Revision 6 (Revision 9-aligned :2025 edition to be issued December 2025) | National standard with some hazard categories not adopted |
| EU | CLP Regulation (EC) No 1272/2008 | Official language of the destination member state | Independent implementation referencing GHS | REACH registration number and UFI required |
| US | OSHA HazCom 2012→2024 | English | Revision 3→Revision 7 (transition in progress) | OSHA PEL, ACGIH TLV, and NIOSH REL listed together |
The UK operates its own GB CLP after Brexit (retained EU CLP law), diverging from EU CLP over time. Canada introduced WHMIS 2015 (GHS Revision 5 base) and updated it to a GHS Revision 7/8 base in December 2022. This article focuses on the EU and US.
EU CLP and Its Relationship to GHS
CLP Regulation does not adopt a specific GHS revision. It operates as an independent regulation that references GHS — the GHS revision number does not map directly to CLP.
Harmonised Classification (Annex VI): Annex VI of CLP lists harmonised classifications decided by ECHA for specific substances. Where a harmonised classification exists, it applies by mandate — a supplier's self-classification cannot override it. These harmonised classifications do not always align with JIS classifications.
New Hazard Classes: Commission Delegated Regulation (EU) 2023/707 (in force April 2023) and Regulation (EU) 2024/2865 (in force December 2024) introduced hazard classes that do not exist in GHS:
- Endocrine disruption (ED Category 1 and 2): human health
- Endocrine disruption (ED Category 1 and 2): environment
- Persistent, Bioaccumulative, and Toxic (PBT / vPvB)
- Persistent, Mobile, and Toxic (PMT / vPvM)
None of these classes exist in JIS Z 7253 or HazCom.
Transition Schedule (as of May 2026):
- Substances first placed on the market from 1 May 2025 onward: new hazard classes apply
- Existing substances (in the supply chain): grace period until 1 November 2026
- Mixtures first placed on the market from 1 May 2026 onward: new hazard classes apply
- Existing mixtures (in the supply chain): grace period until 1 May 2028
Mixtures first entering the EU market from May 2026 already require compliance with the new hazard classes.
US HazCom 2024 Transition
On 20 May 2024, OSHA published the final rule for HazCom 2024, updating the Hazard Communication Standard to align with GHS Revision 7. In January 2026, OSHA extended the compliance deadlines to allow time for regulatory guidance preparation.
The main changes include a new category for desensitized explosives, revised H-statement and P-statement text, and additional SDS requirements.
Compliance deadlines are phased and differ by role — manufacturers, importers, distributors, and downstream users have separate timelines. Check OSHA's official source for the current deadlines.
Note: HazCom 2024 deadlines were revised by OSHA's January 2026 extension notice. Current effective dates are listed at OSHA HazCom effective dates.
Classification Differences
Consider Acute Toxicity Category 5 (oral LD50: 2,000–5,000 mg/kg):
| Region/Standard | Acute Toxicity (oral) Category 5 | Notes |
|---|---|---|
| Japan (JIS Z 7253) | Not adopted | Treated as not classified |
| EU (CLP) | Not adopted | Independent decision from GHS |
| US (HazCom 2012/2024) | Optional (not mandatory) | Manufacturer's discretion |
Japan, the EU, and the US are aligned in not mandating Category 5, which differs significantly from China (GB 30000.1-2024).
Categories and classes where adoption diverges:
| Hazard Class | Japan | EU | US |
|---|---|---|---|
| Acute Toxicity Category 5 | Not adopted | Not adopted | Optional |
| Skin Irritation Category 3 | Not adopted | Adopted | Optional |
| Aspiration Hazard Category 2 | Not adopted | Adopted | Optional |
| Endocrine Disruption (ED) | None | Categories 1 & 2 (from 2023) | None |
| PBT / PMT | None | Yes (from 2023) | None |
The EU adopts Skin Irritation Category 3 and Aspiration Hazard Category 2. Substances listed as not classified in a Japanese SDS may require classification under EU CLP.
Where Translation Fails
Of the 16 SDS sections, a handful can be carried over with translation; most require re-evaluation against local standards.
| Section | Translatable? | Reason |
|---|---|---|
| Section 2 — Hazard Identification | No | EU harmonised classification applies by mandate; HazCom 2024 classification criteria differ |
| H-statements and P-statements | No | Text changes between GHS revisions |
| Section 3 — Composition/Ingredient Information | Verify | EU requires REACH registration number and EC number |
| Section 8 — OEL Values | No | OSHA PEL, ACGIH TLV, NIOSH REL, and EU OELVs are separate values |
| Section 15 — Regulatory Information | No | Translating "Industrial Safety and Health Act (労働安全衛生法)" yields a law name that does not exist in EU or US regulatory frameworks |
| Section 1 — Emergency Contact | Verify | EU: UFI required. US: local emergency contact number required |
| Sections 4–7, 9–12 | Mostly yes | Physical data and procedures are largely transferable, though Section 11 must align with Section 2 |
Some typical problems when applying a straight translation:
| Action | What appears in the SDS | Problem |
|---|---|---|
| Translate Section 15 "労働安全衛生法" to English | Industrial Safety and Health Act | This law does not exist in EU or US regulatory frameworks |
| Translate H302 "飲み込むと有害" to English | Harmful if swallowed | HazCom 2024 has revised the text of some H-statements |
| Carry over Japanese control concentrations (管理濃度, mandatory administrative exposure values under Japan's Industrial Safety and Health Act) as-is | 50 ppm (Japan 管理濃度) | OSHA PEL, ACGIH TLV, and NIOSH REL are separate values |
| Translate "Skin irritation: not classified" to English | Not classified | EU CLP classifies some of these substances as Category 3 |
| Omit REACH information | (no entry) | EU requires REACH registration number and UFI |
Do not translate H-statement and P-statement text
Translating the Japanese text of H302 ("飲み込むと有害") into English may not match the official HazCom 2024 wording. Look up the H- or P-statement number and use the official text from the destination country or region. Because HazCom 2024 revised some H-statements and P-statements, the GHS Revision 3 text used in HazCom 2012 SDSs cannot simply be carried forward.
Section 15 requires a complete rewrite, not a translation
"Industrial Safety and Health Act" — the literal English rendering of 労働安全衛生法 — does not correspond to any EU or US statute. For EU SDSs, list REACH Regulation, CLP Regulation, and the implementing legislation of the destination member state. For US SDSs, list the OSHA Hazard Communication Standard (29 CFR 1910.1200), TSCA, and SARA Title III.
Section 8: OEL Comparison
| Region | Reference Standard | Metric | Legal Force |
|---|---|---|---|
| Japan | Control concentrations (管理濃度, mandatory administrative exposure values, appended to Industrial Safety and Health Ordinance); JSOH (Japan Society for Occupational Health) recommended values | TWA equivalent | Control concentrations are mandatory |
| EU | EU Occupational Exposure Limit Values (OELVs); national OELs of individual member states | TWA, STEL | Most EU OELVs are indicative (non-binding health-based values); Binding OELVs (BOELVs) are mandatory minima. Member states must establish national OELs at least as strict as BOELVs. |
| US | OSHA PEL (29 CFR 1910 Subpart Z) | TWA | Mandatory (many values date to 1971 and have rarely been updated) |
| US | ACGIH TLV (American Conference of Governmental Industrial Hygienists) | TLV-TWA, TLV-STEL | Not legally binding (widely used as the practical standard) |
| US | NIOSH REL (National Institute for Occupational Safety and Health) | TWA, STEL | Not legally binding |
US SDSs in practice list all three — OSHA PEL, ACGIH TLV, and NIOSH REL — together. Many OSHA PELs date to 1971 and are well below current health risk assessments. Japanese control concentrations and JSOH recommended values cannot be substituted for any of these.
For EU SDSs, confirm both the EU OELVs and the national OELs of the destination member state. EU OELVs set the floor; individual member states may set stricter values.
EU-Specific Requirements
REACH Registration Number
Substances registered with ECHA under REACH are assigned a registration number (format: 01-XXXXXXXXXX-XX-XXXX), which goes in Section 3. Japanese chemical manufacturers cannot register directly under REACH, but the number obtained by the EU importer or Only Representative must be confirmed and included in the SDS.
An SDS without a confirmed registration number prevents EU downstream users from fulfilling their regulatory obligations.
UFI (Unique Formula Identifier)
The UFI links a mixture's composition to the notification submitted to the Poison Centre. Under Regulation (EU) 2017/542, UFIs are required — phased in from 2021 — on SDSs and labels for hazardous mixtures. UFIs are generated using the ECHA tool. Japanese SDS formats have no equivalent field.
Extended SDS (eSDS)
When a substance requires a Chemical Safety Assessment (CSA) under REACH, an Exposure Scenario must be attached to the SDS — producing an extended SDS (eSDS). The receiving party must review the attached scenarios to confirm their conditions of use fall within the documented scope.
US-Specific Requirements
California Proposition 65
California's Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65) requires warning labels for products containing listed carcinogens or reproductive toxins above specified thresholds. For products sold in California, note applicable Prop 65 substances in Section 15 and add the required warning on product labels.
SARA Title III
The Superfund Amendments and Reauthorization Act (SARA) Title III requires facilities to report storage and releases of certain hazardous chemicals to the Local Emergency Planning Committee (LEPC). Section 15 should note the applicable sections: Section 302 (EHS list), Section 304, Section 311/312, and Section 313 (TRI reporting).
TSCA
Section 15 should indicate whether each substance appears on the TSCA Section 8(b) Chemical Substance Inventory.
Localization Requirements by Section
Sections that always require localization
| Section | Changes Required |
|---|---|
| Section 2 — Hazard Identification | Apply CLP harmonised classification (EU); apply HazCom 2024 classification criteria (US) |
| Section 3 — Composition/Ingredient Information | REACH registration number and EC number (EU); confirm TSCA inventory listing (US) |
| Section 8 — Exposure Controls/Personal Protection | Replace with EU OELVs and destination member state OELs (EU); list OSHA PEL/TLV/NIOSH REL (US) |
| Section 15 — Regulatory Information | Rewrite for REACH/CLP (EU) or OSHA HazCom/TSCA/SARA (US) |
Sections frequently requiring changes
| Section | Changes Required |
|---|---|
| Section 1 — Identification | UFI (EU); local emergency contact number |
| Section 13 — Disposal Considerations | Local legislation: EU Waste Framework Directive (WFD), US RCRA, etc. |
| Section 14 — Transport Information | UN numbers are shared, but DOT (US) and ADR (EU road) have different notation requirements |
Checklists
Checklist: Japanese SDS → EU SDS
- Section 1: Is a UFI included? (required for hazardous mixtures)
- Section 1: Is the emergency contact number valid in the destination member state?
- Section 2: Where Annex VI harmonised classification exists, is it applied?
- Section 2: Has the substance been checked against the new hazard classes in (EU) 2023/707 and (EU) 2024/2865 (endocrine disruption, PBT/PMT)?
- Section 3: Is the REACH registration number included?
- Section 8: Are OEL values based on EU OELVs and the national OELs of the destination member state?
- Section 15: Are REACH Regulation, CLP Regulation, and the destination member state's implementing legislation listed?
- Language: Is the SDS in the official language of the destination member state?
Checklist: Japanese SDS → US SDS
- Section 2: Is the classification done under HazCom (2012 or 2024) criteria?
- Section 8: Are all three standards — OSHA PEL, ACGIH TLV, and NIOSH REL — listed?
- Section 15: Are OSHA Hazard Communication Standard (29 CFR 1910.1200), TSCA, and SARA Title III (where applicable) listed?
- Section 15: For products sold in California, are applicable Prop 65 substances noted?
- Language: Is the SDS in English?
- HazCom 2024 transition: Have the current OSHA compliance deadlines been confirmed?
Summary
"GHS-based" is the common thread, but classification systems, mandatory content, applicable law, and update obligations differ across regions.
As of May 2026:
- EU: CLP has its own classification system. The 2023 regulatory updates — (EU) 2023/707 and (EU) 2024/2865 — added new hazard classes including endocrine disruption. Mixtures first entering the EU market from May 2026 must comply. The main differences from Japanese SDSs are the REACH registration number and UFI requirements, and the mandatory application of harmonised classification.
- US: Transition to HazCom 2024 (GHS Revision 7 base) is ongoing. OSHA extended the compliance deadlines in January 2026 — check the OSHA website for current dates. The practice of listing OSHA PEL, ACGIH TLV, and NIOSH REL together in Section 8 remains unchanged.
- Japan: JIS Z 7253:2025 (aligned to GHS Revision 9) is due for mandatory enforcement by 2030, with a periodic review obligation in effect since 2023.
A translated Japanese SDS is missing the REACH registration number, UFI, and harmonised classification for EU use — and the OSHA-required OEL entries and SARA/TSCA information for US use. Working from a Japanese source, the localization work typically exceeds the translation work.
Top comments (0)