Somewhere in your raw material portfolio sits an ingredient classified as a skin sensitiser, an aerosol propellant classified for pressure hazards, or a UV filter carrying an environmental hazard statement, each with a safety data sheet and a label built around a specific set of GHS criteria. The European Commission has just proposed rewriting several of those criteria, covering skin sensitising mixtures, chemicals under pressure, and substances hazardous to the atmosphere, to bring the EU's CLP Regulation into line with the UN's more recent GHS revisions, with adoption expected before the end of 2026. Every raw material exported into the EU under those classifications will eventually need to be reassessed against the new criteria, not the ones your SDS was built on.
For a South African raw material manufacturer, the practical shift is this. Your classification, your SDS, and your label do not update themselves the moment the EU changes the rulebook, and a raw material that is correctly classified at home can still fall out of step with what your EU customer's own supply chain now requires. That gap sits with whoever owns chemicals classification and safety compliance in your business, not with the export or sales team who simply ship the drum, because once a formulator or brand in the EU receives your material, the classification travelling with it is expected to meet EU criteria, not South African ones.
South Africa is not without its own GHS regime, and it is worth being precise about what that regime actually says. The Department of Employment and Labour's Hazardous Chemical Agents framework already requires GHS based classification, labelling, and safety data sheets from manufacturers, importers, and suppliers, and as of 1 July 2025 that requirement runs on the tenth revision of the UN GHS, not an old or lapsed one. The genuine gap sits one revision further on. The EU's proposed update draws on the eleventh revision to finish work the tenth started, extending the newer skin sensitising criteria from substances to mixtures, splitting the old ozone hazard class into two separate atmospheric hazard classes covering ozone depletion and global warming, clarifying how aerosols and chemicals under pressure are classified once they sit outside their transport packaging, and formally recognising specific non-animal test methods for skin sensitisation rather than only permitting them informally. None of that sits inside South African law yet, not because South Africa lags on GHS generally, but because the eleventh revision only reached international level in September 2025 and South Africa has not yet had the opportunity to adopt it.
The sensible response is not to wait for the amendment to enter into force. Cross check every raw material currently exported into the EU against the classes the eleventh revision touches, skin sensitising mixtures specifically rather than only substances, pressurised or aerosol forming materials, and substances carrying an atmospheric hazard statement, and confirm with your customer's own regulatory team which SDS and label version they will expect once the amendment takes effect, twenty days after it is published in the Official Journal. Where a reclassification looks likely, get ahead of it in your own documentation rather than waiting for a customer query or a stopped shipment to force the issue, and keep a clear internal record of which GHS revision each classification is currently pegged to, since South Africa's own regulation moved from revision eight straight to revision ten in one step and is likely to move again.
Bottom Line Take Out
The EU is not creating a new obligation out of nothing, it is finishing the same GHS revision cycle South Africa has already been keeping pace with, just one step ahead of where South African law currently sits. Raw material manufacturers exporting into the EU should treat this as a live compliance question now, not a future one, given the amendment is expected in force before the end of 2026. Reassess classifications tied to skin sensitising mixtures, pressurised materials, and atmospheric hazards ahead of that date, and put chemicals management and safety, not sales, in charge of the answer. A raw material that is fully compliant at home can still be non-compliant the moment it crosses into the EU's supply chain.
References
EU CLP Update: Aligning with Recent UN GHS Revisions (National Law Review) South Africa Implements GHS Revision 10 for Classification and Labelling from 1 July 2025 (GPC Gateway) UN GHS Rev 11 (2025): All Changes Explained (GHS Pictograms)
