The Brazilian Technical Standards Association (ABNT) published the revised GHS national standard ABNT NBR 14725:2023 on July 3, 2023, and it will formally go into effect on July 4, 2025. Three essential operational criteria for businesses to guarantee SDS and GHS label compliance are outlined in this thorough examination.

I. GHS Classification Updates

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

Solid or liquid explosive materials or mixes whose explosive qualities have been subdued by treatment are referred to as desensitized explosives, a new physical threat. The UN Manual of Tests and Criteria’s corrected burning rate (Ac) serves as the basis for classification. There are four types of desensitized explosives: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.

Category 1A and Category 1B are further divisions of flammable gas Category 1. Gases that exhibit chemical instability or pyrophoric characteristics are automatically categorized as Category 1A.

3. Significant changes to health hazards.

ABNT NBR 14725:2023 tightens the requirements for applying thresholds and concentration limits to categorize mixtures and offers more thorough classification criteria based on UN GHS Revision 7. Important modifications consist of:

· 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

GHS labels will undergo numerous important modifications following the adoption of ABNT NBR 14725:2023, particularly with regard to tiny container labels and the labelling requirements for products that are not classified under GHS.

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

a) Product identification.

b) Supplier identification.

c) 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 labelling requirements are as follows:

a) Product identification – Not updated.

b) Supplier identification – Not updated.

c) Chemical component names – Mandatory only for components with health hazards (but note that the SDS must include all components with health and environmental hazards);

d) Hazard pictograms – Not updated.

e) Signal words – “Danger” and “Warning” retained; the word “Caution” has been removed.

f) Hazard statements (H phrases) – Added hazard statements such as H206 and H207, and revised hazard statements such as H270 and H314.

g) 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.

h) 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

Additionally, GHS labels and SDS must be provided in Portuguese in accordance with ABNT NBR 14725:2023 because Portuguese is Brazil’s national language. Companies that export to Brazil as chemical suppliers must quickly determine if the SDS and GHS labels they presently use meet ABNT NBR 14725:2023 criteria and start updating them right away. It’s advisable to check with Brazilian clients beforehand, especially with relation to the new SDS requirement for a 24-hour emergency consultation phone number. In order to prevent problems like cargo detention at ports brought on by extended delegation periods, it is highly advised to begin the delegation work as soon as possible if third-party emergency phone services are needed, leading to unnecessary complications.