Chemical Hazard Pictograms (GHS) in Malaysia: How to Make a CLASS 2013 Label

In Malaysia, the classification, labelling and safety data sheets of hazardous chemicals are governed by the Department of Occupational Safety and Health (DOSH) under the Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013 — the so-called CLASS Regulations 2013 (P.U.(A) 310/2013, gazetted on 11 October 2013) — empowered by the Occupational Safety and Health Act 1994 (OSHA 1994, Act 514), and adopting the United Nations Globally Harmonised System (GHS). For any chemical supplied or used in the workplace and meeting the hazard classification, the supplier has a duty to produce a compliant GHS label: the red-bordered diamond hazard pictogram, signal word, hazard statements and precautionary statements are all indispensable.

GHS hazard pictograms: nine red-bordered diamonds

The CLASS Regulations only permit red-bordered diamond pictograms (black symbol, white background, red border); black borders or other colours are not accepted. GHS has nine pictograms in total, corresponding to different hazard classes:

Which ones you actually place depends on the hazard classification result of the substance. Be sure to follow SDS Section 2 and the supplier's classification, and do not add or remove any on your own.

The six mandatory label elements

A compliant CLASS/GHS label must have at least:

1. Product identifier (a name consistent with the SDS)
2. Supplier identification (name, address, telephone)
3. Hazard pictogram (red-bordered diamond)
4. Signal word (Danger / Warning, choose one)
5. Hazard statements (H phrases)
6. Precautionary statements (P phrases)

Size, font size and language

• Pictogram size: each hazard pictogram must have an area of at least one-fifteenth (1/15) of the total label area, and no smaller than 10 mm × 10 mm.
• Font size: label text must be at least 7 point and clearly legible.
• Language: the label must be presented in both Malay and English.
• Small-package exemption: very small-capacity packages (the industry commonly cites a ≤125 ml threshold) may omit the hazard/precautionary statements, but must add a prompt such as "read SDS before use"; confirm the actual scope of exemption against the text of the CLASS Regulations and DOSH guidance.

Imported vs local

The CLASS Regulations govern hazardous chemicals "supplied or used in a Malaysian workplace" and grant no exemption based on origin: imported chemicals must equally carry a bilingual Malay-English GHS label and SDS when entering the supply chain, and the supplier identification on the label must usually resolve to a supplier/importer within Malaysia, not merely list the overseas manufacturer. Pay particular attention to the scope boundary — consumer products, cosmetics, food, medicines, pesticides and so on each have their own dedicated regulations (such as NPRA or the Pesticides Board) and do not necessarily follow CLASS; determining "which piece of legislation this product actually falls under" is the first step.

Label and SDS, secondary containers

The GHS label is not a standalone document; it must be consistent with the Safety Data Sheet (SDS): the product identifier, hazard pictograms, signal word and H/P phrases on the label should all be traceable to the SDS. When a chemical is decanted into a secondary container on the work site (such as a small drum or spray bottle), in principle it must still bear markings by which the hazard can be identified — you cannot leave a blank container for on-site personnel to operate from memory. The supplier (manufacturer, importer, distributor) must have the label and SDS ready at the point of supply, and update them in sync when the formulation or hazard classification changes — an old label with a new SDS, or vice versa, is a common demerit in inspections.

Common mistakes

• Using a black border or coloured pictogram: CLASS only recognises the red border; the wrong colour is equivalent to invalid.
• Pictogram too small: below 1/15 or 10×10 mm is non-compliant.
• English only, missing Malay: bilingual is a hard requirement.
• H/P phrases inconsistent with the SDS: classification and phrases must match the safety data sheet.
• Choosing pictograms on your own: adding or removing pictograms from memory may miss a key hazard.
• Supplier listing only the overseas maker: missing local supplier/importer information leaves traceability and accountability without a basis.

Frequently asked questions (FAQ)

Q: Do all chemicals need a GHS label? No. Only chemicals that meet the CLASS hazard classification and are supplied/used in a workplace need one; whether a product falls within scope depends on the classification result and the nature of the product.

Q: Can the pictogram use a black border? No. The CLASS Regulations only permit red-bordered diamond pictograms.

Q: Must the label be bilingual Malay-English? Yes. The CLASS label requires presentation in both Malay and English.

Q: What if a very small bottle cannot fit all the information? Very small packages may be simplified as provided, usually retaining the pictogram and identification and adding a prompt to read the SDS; the exact threshold and the items that may be omitted follow the Regulations and DOSH guidance.

Q: Do consumer cleaning products also follow CLASS? It depends on positioning. CLASS targets workplace hazardous chemicals; purely consumer, cosmetic, food and medicinal products each have their own dedicated law, and which one applies must be clarified first.

Self-check list

• [ ] Hazard classes and corresponding pictograms confirmed per the SDS and supplier classification
• [ ] Pictograms are red-bordered diamonds, area ≥ 1/15 of the label and ≥ 10×10 mm
• [ ] All six elements present (product/supplier identification, pictogram, signal word, H, P)
• [ ] Text ≥ 7 point, bilingual Malay and English
• [ ] Supplier identification resolves to a supplier/importer within Malaysia
• [ ] Confirmed whether the product falls under CLASS, or should belong to another governing regulation

Conclusion

A chemical label in Malaysia is not an art exercise but a safety-regulation exercise: pin down DOSH's CLASS Regulations 2013, the red-bordered diamond pictograms, the six elements, the 1/15 or 10×10 mm pictogram size and bilingual Malay-English, and make the H/P phrases fully consistent with the SDS, and you hold the baseline. The first step is always to determine which piece of legislation the product actually falls under.

Run a free label check now

Further reading: hazardous chemicals CLASS regulations, Malaysia market-entry master roadmap, round-up of common label rejection reasons.

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