Written on: December 1, 2025 by Cassandra Taylor
A new wave of chemicals regulation is taking shape across major jurisdictions:
1. The United Nations (UN) has issued the 11th revised edition of the Globally Harmonized System of Classification & Labeling of Chemicals (GHS);
2. China is moving to modernize labeling and update parts of its GHS-based system; and
3. Brazil is advancing its national risk management framework and chemical inventory requirements.
As global chemical regulatory activity continues at a steady pace, these three developments stand out as broad, forward-looking initiatives worthy of attention.
UN publishes GHS Revision 11
The UN released the 11th revised edition of GHS, adding several changes of direct relevance to the aerosol sector. The revision is now publicly available for download.
Among the most significant amendments are new provisions clarifying the distinction between aerosols and chemicals under pressure. Aerosols are distinguished by the presence of a release device that ejects suspended particles, whereas Chemicals Under Pressure are products in pressurized receptacles that are not aerosol dispensers and contain 50% or more by mass of solids or liquids. The amended definitions also make clear that these categories are separate from other physical hazards. Products classified as Aerosols or Chemicals Under Pressure cannot simultaneously be classified as Flammable Gases, Gases Under Pressure or Flammable Solids/Liquids. In addition, the criteria for Aerosols (Category 1) have been amended to include any aerosol containing more than 1% flammable components or with a heat of combustion of at least 20 kJ/g when the product has not been tested according to the applicable ignition or foam-flammability methods.
GHS also introduces a new hazard concept related to environmental classification. Chapter 4.2 has been renamed from “Hazardous to the ozone layer” to “Hazardous to the atmospheric system” to reflect that substances may pose hazards through ozone depletion and/or contributions to global warming. The GHS now includes a definition of Global Warming Potential (GWP) and establishes two possible classifications for products: Hazardous to the Ozone Layer, based on Ozone Depleting Potential (ODP), and Hazardous by Contributing to Global Warming, based on GWP. The classification criteria for each category reference the annexes of the Montreal Protocol, which list chemicals with ODP or GWP values that are considered hazardous to the atmosphere. A new hazard statement has been added: “Harms public health and the environment by contributing to global warming.” A combined statement may be used when both ozone depletion and global warming criteria are met: “Harms public health and the environment by contributing to global warming and destroying ozone in the upper atmosphere.”
GHS introduces a new section in Annex 11 addressing simple asphyxiants, which are gases or vapors that displace oxygen and can lead to unconsciousness or death by oxygen deprivation. The annex provides examples of substances commonly considered simple asphyxiants, including carbon dioxide, hydrogen, nitrogen, helium, neon, argon, krypton, xenon, ethane, ethylene, acetylene, methane, propane, propylene, aliphatic alkanes and the chlorofluorocarbons. It also clarifies that a separate identification as a simple asphyxiant is not warranted when a substance is already classified for acute inhalation toxicity. The annex offers guidance on hazard communication for these substances and points to existing regulations and reference standards on safe handling in oxygen-reduced environments.
Updates were made to improve the clarity and usability of precautionary statements. The “specific treatment” P-statements (P320/P321) were amended to reference both the label and the Safety Data Sheet (SDS) when immediate measures are easily applied. New P-statements (P322/P323) were added that refer only to the SDS when more detailed instructions are necessary for treatment. Other changes include revisions to Annex 7 to more accurately reflect the classification categories shown in the label examples, along with new guidance on classifying skin sensitizers using non-animal test methods.
Adoption of GHS revisions varies globally, as each country determines which edition to implement and which specific building blocks to adopt. Most jurisdictions remain several editions behind, with the more proactive countries currently aligned with Revision 8 or Revision 9. Although the latest updates are not yet in force in most regions, they offer early clarity for classification decisions and provide insight into the direction of future regulatory developments worldwide.
China transitions toward updated GHS revisions
In August 2025, China’s Ministry of Industry & Information Technology (MIIT) released for public comment a draft of the new mandatory national standard “Regulations on the Preparation of Chemical Safety Labels,” outlining updated requirements for the design, preparation and application of chemical safety labels. The draft proposes to replace the existing “GB 15258 General Rules for Preparation of Chemical Safety Labels,” which has been in force since 2009. It introduces new elements including the use of a QR code for chemical safety information, new rules for small packages and fold-out labels, simplified label rules and kit packaging examples. The updated labeling rules are aligned with the 10th revised edition of GHS. The consultation period has closed, and although the enforcement date has not yet been announced, a one-year transition period is expected following final publication.
In July 2024, China’s Standardization Administration (SAC) issued GB 30000.1, the new general rules for chemical classification and labeling under the GB 30000 series. GB 30000.1 serves only as a general chapter. It defines acceptable hazard endpoints and clarifies what constitutes an SDS and a GHS label in China but does not set out how substances or mixtures are to be classified. Instead, it directs users to follow GB 30000.2 through GB 30000.29.
In June 2025, MIIT released GB 30000.30 on Desensitized Explosives. Although it has little relevance to aerosol manufacturers, as aerosols cannot be classified as explosives, GB 30000.30 formally introduces Desensitized Explosives as a new classification category.
Aside from this new endpoint, China’s classification chapters GB 30000.2–29 remain aligned with GHS Revision 4 and have not yet been updated. As a result, China is now effectively operating a mixed-revision system: GHS Revision 4 for GB 30000.2–29, GHS Revision 8 for GB 30000.1 and GHS Revision 10 for the newly added Desensitized Explosives category under GB 30000.30. No timeline has been announced for updating the remaining chapters.
Brazil continues work on draft chemicals law
Brazil’s Ministry of Environment & Climate Change (MMA) released a draft implementing regulation for the Chemical Management Law (also known as Brazil REACH), aimed at operationalizing Law No. 15,022/2024. Notably, the draft was published in both Portuguese and English, making it more accessible to international audiences. Rather than running a formal public consultation, the MMA had invited interested parties to submit comments and suggestions by email by Sept. 1 of this year.
The proposed regulation establishes the framework for creating a national inventory of chemicals and for assessing and managing the risks of substances manufactured, used or imported in Brazil. Risk management measures could include restrictions on production and use, prior authorization requirements or even prohibition of certain substances.
A new registration platform will be developed within three years. Once operational, companies will have an additional three years to register existing chemicals, forming the Brazilian Chemical Substance Inventory. Chemicals manufactured or imported in Brazil in quantities equal to or greater than one ton per year—based on a three-year average—will require registration. Registrants will need to provide importer or producer details, production or import volumes, substance information, chemical risk analyses based on recommended uses and any applicable fees.
The regulation also allows foreign manufacturers to appoint local entities as representatives, much like the “Only Representative” model in the EU. The legislation will introduce a process for prioritizing substances for risk assessment and for defining and implementing risk management measures, taking into account human health; environmental protection; and social, economic and technological factors. This marks a move toward a more structured and transparent chemicals management system and aligns Brazil with broader global regulatory trends. SPRAY
