Mandatory Implementation of Brazil's New GHS Standards Effective July 4, 2025: Are Your SDS and Labels Compliant?

Brazil's updated GHS national standard ABNT NBR 14725:2023, released by the Brazilian Technical Standards Association (ABNT) on July 3, 2023, officially takes effect on July 4, 2025. This comprehensive analysis outlines three key operational requirements for enterprises to ensure SDS and GHS label compliance.

I. GHS Classification Updates

1. Two new GHS categories have been added: 'Desensitized Explosives' and 'Hazardous to the Ozone Layer.'

Desensitized Explosives, a new physical hazard, refer to solid or liquid explosive substances or mixtures whose explosive properties have been suppressed through treatment. Classification is based on the corrected burning rate (Ac) from the UN Manual of Tests and Criteria. Desensitized Explosives are divided into four categories:

• Category 1: Ac ≥ 300 kg/min and ≤ 1200 kg/min;
• Category 2: Ac ≥ 140 kg/min and ≤ 300 kg/min;
• Category 3: Ac ≥ 60 kg/min and ≤ 140 kg/min;
• Category 4: Ac < 60 kg/min

Hazardous to the Ozone Layer, a new environmental hazard, includes all substances listed in the Montreal Protocol annex (e.g., HFCs) or mixtures containing these substances at ≥ 0.1%.

2. Adjustments to the classification of flammable gases.

Flammable gas Category 1 has been further subdivided into Category 1A and Category 1B. Gases with pyrophoric or chemically unstable properties are automatically classified as Category 1A.

3. Significant changes to health hazards.

Based on UN GHS Revision 7, ABNT NBR 14725:2023 provides more detailed classification criteria and strengthens requirements for using thresholds and concentration limits to classify mixtures. Key changes include:

• Reproductive toxicity: The hazard classification name has been updated from 'Reproductive and Lactation Toxicity' to 'Reproductive Toxicity,' aligning with GHS.
• Skin corrosion/irritation: When the subcategories (1A, 1B, or 1C) cannot be accurately determined, Category 1 is also allowed to be formally used as a general category. At the same time, skin corrosion/irritation also includes two classifications: Category 2 and Category 3.
• Serious eye damage/eye irritation: For Category 2, it can be clearly subdivided into: 2/2A – Eye irritation, 2B – Moderately reversible eye irritation. Additionally, the content of Category 1 remains unchanged.
• Respiratory or skin sensitization: Clearly introduces subcategories – Category 1, Category 1A, and Category 1B.
• Acute toxicity (inhalation, gases): Updates the ATE value (Acute Toxicity Estimate) corresponding to Category 4.

II. GHS Label Updates

After the implementation of ABNT NBR 14725:2023, there are many significant changes to GHS labels, especially for small container labels and the labeling requirements for products without GHS classification, which have major updates.

1. For products without GHS classification, the new standard requires the label to include the following information:

1. Product identification;
2. Supplier identification;
3. Mandatory statement: "No hazard classification according to ABNT NBR 14725" or "No hazard classification according to UN GHS".

2. For products with GHS classification, under the new standard, the labeling requirements are as follows:

1. Product identification – Not updated;
2. Supplier identification – Not updated;
3. Chemical component names – Mandatory only for components with health hazards (but note that the SDS must include all components with health and environmental hazards);
4. Hazard pictograms – Not updated;
5. Signal words – "Danger" and "Warning" retained; the word "Caution" has been removed.
6. Hazard statements (H phrases) – Added hazard statements such as H206 and H207, and revised hazard statements such as H270 and H314.
7. Precautionary Statements (P terms) - Added new precautionary statements such as P102, P112, revised statements like P103, P104, and removed statements such as P221, P235+P410.
8. Supplemental Information - Under the new standard, SDS must indicate that it 'may' be obtained, rather than the previous requirement that it must be obtainable.

3. Labeling requirements for small containers:

Packaging ≤ 250ml may use alternative methods such as fold-out labels, hang tags, or intermediate packaging labels.

III. SDS Requirements

1. Document Renaming: FISPQ changed to FDS (Ficha de Dados de Segurança, Safety Data Sheet in Portuguese)
2. Section Updates:

• Section 1: Mandatory 24/7 emergency phone number with Brazilian local service
• Section 3: Requires chemical names, CAS numbers, and concentration data for hazardous components
• Section 9: Particle size data required for solid substances/mixtures

Furthermore, since the official language of Brazil is Portuguese, both GHS labels and SDS, according to ABNT NBR 14725:2023, must be provided in Portuguese.

For companies exporting to Brazil, as chemical suppliers, it is necessary to promptly check whether the currently used SDS and GHS labels comply with the requirements of ABNT NBR 14725:2023 and initiate updates as soon as possible. Particularly regarding the new SDS requirement for a 24-hour emergency consultation phone number, it is advisable to confirm with Brazilian clients in advance. If third-party emergency phone services are required, due to the lengthy delegation process and timeline, it is strongly recommended to start the delegation work early to avoid issues such as cargo detention at ports caused by prolonged delegation periods, leading to unnecessary complications.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.