Malaysia Hazardous Chemicals CLASS Regulations: Classification, Labelling and the Full SDS Obligations

Manufacturers, formulators, importers and distributors who supply "hazardous chemicals" in Malaysia must comply with the Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013, commonly known in the industry as the CLASS Regulations 2013 (P.U.(A) 310/2013), administered by the Department of Occupational Safety and Health (DOSH / JKKP) under the Ministry of Human Resources pursuant to the Occupational Safety and Health Act 1994 (OSHA 1994). They replaced the former CPL Regulations 1997 and fully aligned Malaysia's chemical hazard communication system with the United Nations Globally Harmonized System (GHS). There are three core obligations: classification, labelling and the SDS (safety data sheet), plus a once-a-year chemical inventory submission. This framework targets industrial and commercial chemicals supplied in the workplace; cosmetics, pharmaceuticals, pesticides and food have their own separate competent authorities and are outside the CLASS scope.

Who must comply, and what is regulated

CLASS applies to anyone who supplies hazardous chemicals in the workplace — covering manufacture, formulation, import and distribution. Those with an annual supply of 1 tonne or more must be included in the inventory submission; radioactive materials, waste, cosmetics, pharmaceuticals, pesticides, chemicals merely in transit, and R&D quantities of 5 kg or less are excluded. Whether a substance is "hazardous" is judged under the GHS classification criteria adopted in DOSH's Industry Code of Practice on Chemical Classification and Hazard Communication 2014 (ICOP on Chemical Classification and Hazard Communication 2014); Malaysia currently corresponds to GHS Revision 3 and has begun amending the law to move towards a newer version.

The three core obligations

• Classification: determine the categories and grades of physical, health and environmental hazards under GHS.
• Labelling: the container label must include the product identifier, supplier details, hazard pictograms, signal word (Danger / Warning), hazard statements (H-phrases) and precautionary measures (P-phrases). The label must be presented bilingually in Malay and English.
• SDS (safety data sheet): use the fixed GHS 16-section structure, likewise available in both Malay and English, provided to downstream users at the point of supply; the content must be maintained as data is updated.

Chemical inventory submission

Manufacturers and importers must compile a chemical inventory year by year, stating the product identifier, chemical name, composition, hazard classification and total annual supply, submitted through DOSH's CIMS (Chemical Information Management System) online system by 31 March of the following year. The handling of confidential business information (CBI) is applied for under the relevant chapters of the ICOP.

Import vs local supply differences

A local manufacturer completes classification and the SDS at the production end; importers take on a "gatekeeper" role — even if the overseas supplier has already attached an English SDS and label, the importer must still confirm that the classification matches the GHS version adopted in Malaysia, add the Malay, and include the item in the CIMS annual inventory under its own name. Relying solely on the original manufacturer's English documents without localisation is the most common form of violation.

Common mistakes

• The label or SDS in English only, missing Malay.
• The SDS carrying over an EU CLP or other-system format, not aligned with the GHS 16 sections and the version adopted in Malaysia.
• Pictograms, signal word and H/P statements inconsistent with the classification result (for example, classified as Danger but marked as Warning).
• The importer mistakenly assuming "it's fine if the manufacturer did it", not localising and not submitting the CIMS inventory.
• Wrongly placing consumer cleaning products or cosmetic-type products into CLASS, or conversely ignoring the CLASS obligations for industrial-use ingredients.

Household cleaning and disinfectant products, if they contain hazardous ingredients, may equally fall into CLASS at their workplace supply stage; the consumer labelling at the retail end is separately governed by consumer legislation, and the two must be viewed separately.

Frequently asked questions (FAQ)

Q: Must a CLASS label be in Malay? Is English only acceptable? No. CLASS requires the label and SDS to be in both Malay and English. English only is a common violation, and the importer is responsible for adding the Malay.

Q: My overseas supplier already gave me a GHS label and SDS — what else do I need to do? Yes, there is more. The importer must confirm the classification aligns with the GHS version adopted in Malaysia, complete the bilingual versions, and include the item in the CIMS annual chemical inventory under its own name. The manufacturer's documents do not equal local compliance.

Q: When must the inventory be submitted to DOSH? Chemicals with an annual supply of 1 tonne or more must be submitted through the CIMS online system by 31 March of the following year, reporting the previous year's data.

Q: Is there a required format for the SDS? Yes. It must use the GHS 16-section standard structure, covering fixed chapters such as identification, hazard identification, composition, first aid, firefighting, spillage handling, storage and transport, and exposure control.

Q: Which chemicals are not governed by CLASS? Radioactive materials, waste, cosmetics, pharmaceuticals, pesticides, chemicals in transit, and R&D quantities of 5 kg or less are outside the CLASS scope, but may be governed by other authorities.

Self-check checklist

• [ ] Completed hazard classification under the GHS version adopted in Malaysia
• [ ] The label includes identification, supplier, pictograms, signal word, H/P statements, and is in Malay + English
• [ ] The SDS is a GHS 16-section structure, bilingual, with up-to-date content
• [ ] Pictograms and signal word are consistent with the classification result
• [ ] Those with an annual supply ≥1 tonne have completed the CIMS inventory submission by 31 March of the following year
• [ ] Imported goods are localised, not relying solely on the manufacturer's English documents

Summary

The CLASS Regulations 2013 are the backbone of workplace chemical hazard communication in Malaysia: classification, bilingual labelling, a 16-section SDS, plus the CIMS annual inventory — all four are indispensable. Importers in particular should remember that they are the gatekeeper, and that the manufacturer's documents are only the starting point, not the finish line.

Further reading: overview of household cleaning and chemical labelling, Malaysia market entry roadmap, penalties and enforcement for violations.

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This article is compiled from official sources for reference only; actual compliance is subject to the latest official text and review by the competent authority.