In the United States, chemical labeling requirements are governed by OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, which aligns with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Labels are an important part of hazard communication; they provide critical information to protect workers from chemical exposure risks. Understanding the difference between primary and secondary container labels is essential for compliance with GHS (Globally Harmonized System) standards and keeps your employees safe.
In short: a primary label is the full label the manufacturer, importer or distributor puts on a shipped container, and it must carry all six GHS label elements. A secondary label is the workplace label an employer puts on a container after transferring a chemical into it, and at minimum it needs the product identifier and general information about the hazards.
Key Takeaways
- The main difference between primary and secondary labels is who applies them and what they must show. Primary (shipped container) labels are applied by the manufacturer, importer or distributor and must carry all six GHS label elements. Secondary (workplace) labels are applied by the employer after moving a chemical into another container, and can be simpler.
- At minimum, a secondary label needs the product identifier plus words, pictures or symbols that give general information about the hazards.
- The supplier’s name, address and phone number are required on primary labels but not on secondary labels.
- A portable container used immediately by the worker who filled it does not need a label; once it is shared, left behind or kept for later, it does.
- Never remove or deface the primary label on an incoming container.
What Is a Primary Container Label?
A primary container label is the original label provided by the manufacturer, importer, or distributor on the container in which the chemical is shipped.
OSHA Requirements for Primary Labels: Must include all GHS label elements.
- Product identifier: Matches the name in the Safety Data Sheet (SDS)
- Supplier information: Name, address, and phone number of the responsible party
- GHS pictograms: For all applicable hazard classes
- Signal word: “Danger” or “Warning”
- Hazard statements: Standardized descriptions of hazard types and severity
- Precautionary statements: Guidance on safe handling, storage, and disposal
- Supplementary information (optional): Allowed as long as it does not contradict or cast doubt on the required elements
Example: A gallon of paint thinner shipped from the manufacturer with a label containing the flammable pictogram, “Danger” signal word, and hazard/precautionary statements.
OSHA’s regulation calls this a shipped container label (1910.1200(f)(1)). The rule applies to every container of a hazardous chemical that leaves the workplace, so an employer that ships a chemical onward must label it in the same way. For a step-by-step walkthrough of building one, see how to make a GHS label.
Rules that protect the primary label
- Labels on incoming containers must not be removed or defaced unless the container is immediately relabeled with the required information (1910.1200(f)(9)).
- Labels must be legible, in English (other languages may be added) and prominently displayed (1910.1200(f)(10)).
- The manufacturer, importer or distributor must revise the label within six months of becoming aware of significant new hazard information (1910.1200(f)(11)).
Small containers
When a full label will not fit, even as a fold-back label, pull-out label or tag, OSHA allows a reduced label on containers of 100 ml or less: product identifier, pictogram(s), signal word, the manufacturer’s name and phone number, and a statement that the full label is on the immediate outer package. Containers of 3 ml or less need only the product identifier where a label would interfere with use. The outer package must carry the full label (1910.1200(f)(12)).
What Is a Secondary Container Label?
A secondary container label is used when a chemical is transferred from its primary container into another container for use within the workplace.
Common examples include spray bottles of diluted cleaner, squeeze bottles at a parts washer, jugs of decanted solvent, beakers of a prepared lab solution and day tanks filled from a drum.
When Required Under HazCom:
- Any container holding a hazardous chemical beyond immediate use by the person who transferred it must be labeled.
- Exceptions apply only if: The chemical is used immediately by the employee who transferred it, and The container never leaves their control during use.
Required Elements for Secondary Labels (minimum OSHA requirements):
- Product identifier: Same as on the SDS
- Hazard information: Words, pictures, symbols, or a combination that provides general hazard awareness
- Recommended: Include signal words, hazard statements, and pictograms for clarity
Under 1910.1200(f)(6), employers can meet this requirement in one of two ways: copy the primary label’s elements without the supplier’s contact details, or use the product identifier plus words, pictures or symbols that give at least general hazard information.
OSHA confirmed in a 2017 interpretation letter that the second option does not need hazard statements, precautionary statements or the manufacturer’s details, as long as employees are trained on the system and SDSs are available during every shift. That is also why in-house systems such as NFPA and HMIS labels can serve as secondary labels. For the full rules, see GHS secondary container label requirements.
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When Is a Secondary Label Not Required?
OSHA does not require a label on a portable container that is filled from a labeled container and “intended only for the immediate use of the employee who performs the transfer” (1910.1200(f)(8)). In a 1990 interpretation letter, OSHA added that containers used by anyone else, including employees on other shifts, must be labeled.
| Scenario | Label needed? |
|---|---|
| You fill a spray bottle and use it up yourself during the task | No |
| You fill it, use part of it and leave it on a cart for the next shift | Yes |
| A coworker borrows the bottle | Yes |
| You decant solvent into a jug to use tomorrow | Yes |
| A lab technician prepares a solution and uses it immediately in her own procedure | No |
| A container is left unattended in a shared area | Yes |
| Differences | Primary Container Label | Secondary Container Label |
|---|---|---|
| Created and Applied By | Manufacturer, importer, or distributor | Employer or workplace staff transferring the chemical |
| Content | Full GHS label (product ID, supplier info, pictograms, hazard & precautionary statements) | Minimum: product ID + hazard information; Recommended: pictograms, signal words, hazard statements |
| Purpose | Communicate full hazard and regulatory information to any handler | Communicate hazards to employees in the workplace |
| When Required | On all shipped chemical containers | On all workplace containers not used immediately by the person who filled them |
| Regulatory Basis | OSHA HCS, 29 CFR 1910.1200(f)(1) | OSHA HCS, 29 CFR 1910.1200(f)(6) |
| Product identifier | Required | Required |
| Pictograms | Required | Optional under the (f)(6)(ii) option; common practice |
| Signal word | Required | Optional under the (f)(6)(ii) option |
| Hazard statements | Required | Optional under the (f)(6)(ii) option |
| Precautionary statements | Required | Not required |
| Supplier name, address, phone | Required | Not required |
| NFPA or HMIS instead of GHS | Not allowed | Allowed with employee training |
Primary vs Secondary Label Example
The example below shows the same chemical, acetone, with both labels. The primary label carries all six elements; the secondary label keeps the product identifier and the hazard information and leaves out the supplier details and precautionary statements.
Special Cases: Stationary Containers and Transport Labels
Stationary process containers. For tanks, vats and other fixed containers, employers may use signs, placards, process sheets, batch tickets or operating procedures instead of labels, as long as they identify the container and carry the same information as a workplace label and are readily available to employees during each shift (1910.1200(f)(7)).
Containers shipped as dangerous goods. A drum shipped by road, rail, air or sea may also need DOT transport markings. These sit alongside the primary GHS label rather than replacing it; see GHS labels vs transport labels.
Common HazCom Compliance Mistakes
- Leaving secondary containers unlabeled when shared or stored for later use
- Using abbreviations or chemical codes that employees can’t understand
- Not matching the product name to the SDS exactly
- Failing to update labels when chemical formulations or hazards change
- Removing or covering the manufacturer’s label on incoming containers
- Using labels that fade, smear or peel when they come into contact with the product or cleaning chemicals
- Switching between labeling systems (for example GHS on some containers and HMIS on others) without training employees on both
Quick Answers to Common HazCom Training Questions
Are secondary hazard labels identical to primary hazard labels?
No, secondary hazard labels are not identical to primary hazard labels. A secondary label can carry less information, because supplier details and precautionary statements are not required. Many employers still copy the pictograms, signal word and hazard statements from the primary label so workers see the same warnings on both containers.
Must every shipped container label contain the same elements?
Yes, every shipped container label must contain the same six elements, although their content depends on the chemical’s classification. Two shipped labels can look very different, because one chemical may need three pictograms and “Danger” while another needs one pictogram and “Warning”.
What are the two mandatory pieces of information on a secondary label?
The two mandatory pieces of information on a secondary label are the product identifier and general information about the chemical’s hazards. The hazard information can be words, pictograms, symbols or a combination of them, as long as employees are trained to understand it.
What is not required on a secondary label?
A secondary label does not require the supplier’s name, address and phone number. If the label uses the simpler option allowed under 1910.1200(f)(6)(ii), it also does not need hazard statements or precautionary statements.
A worker transfers a chemical into a container for another employee to use later. What is required?
The container must be labeled with at least the product identifier and general information about its hazards. The immediate-use exemption does not apply, because the container will be used by someone else and at a later time.
Can you move the original label onto the secondary container?
No, you cannot move the original label onto the secondary container. The label on the incoming container must stay in place, so make a new label for the secondary container. Removing the original label leaves the source container unmarked, which 1910.1200(f)(9) prohibits unless the container is relabeled immediately.
Do primary and secondary labels both include the product identifier?
Yes, primary and secondary labels both include the product identifier, and it must match the SDS. This is how a worker holding either container finds the right safety data sheet.
Is labeling every secondary container best practice?
Yes, labeling every secondary container is best practice. Even where the immediate-use exemption applies, a label prevents mix-ups if the container is set down or shared. Unlabeled spray bottles and jugs are one of the most common workplace-label gaps found in inspections.
The Easy Way to Stay Compliant
Manual creation of compliant secondary labels can be slow and error-prone. SDS Manager’s free GHS Secondary Label Generator allows you to:
- Auto-fill hazard information directly from your SDS
- Support multiple label sizes and layouts
- Add OSHA-compliant GHS pictograms and hazard statements automatically
- Include QR codes linking directly to the SDS for instant access
With automation, you can maintain compliance, save time, and reduce labeling errors across your workplace.
If you manufacture or import chemicals and need full primary labels, ExactSDS, SDS Manager’s SDS authoring software, generates GHS labels from the same data as the SDS you create.
Frequently Asked Questions (FAQs)
What is the main difference between primary and secondary container labels?
The main difference between primary and secondary container labels is who applies them and how much information they must carry. Primary labels are applied by the manufacturer, importer or distributor and must include all six GHS label elements. Secondary labels are applied by the employer when a chemical is transferred into another container, and they can be simpler: the product identifier plus general information about the hazards.
Do all secondary containers need a label?
Yes, all secondary containers need a label, unless the container is filled from a labeled container and intended only for the immediate use of the person who filled it. If it is shared, left unattended or kept for later, it must be labeled. In practice, most workplaces label every secondary container, because it is hard to guarantee that a container will never be set down or handed to someone else.
Can I handwrite secondary container labels?
Yes, you can handwrite secondary container labels, as long as they are legible, durable, in English and include the required hazard information. Use a marker that resists the chemical in the container, and replace the label if it fades or smears.
Do secondary labels need pictograms?
No, secondary labels do not strictly need pictograms under OSHA, as long as the label gives general hazard information in words or symbols that employees are trained to understand. Including the relevant GHS pictograms is still best practice, because workers recognize them at a glance. If you copy the full primary label onto the secondary container, the pictograms are part of it.
How can I make sure my labels are OSHA-compliant?
You can make sure your labels are OSHA-compliant by building them from the current SDS and checking each element against Section 2. Use the product identifier exactly as it appears on the SDS, keep labels legible and in English, and review them whenever the SDS is revised. Train employees on how to read your labels, because a workplace label using the simpler option is only compliant if workers understand it.
Is a primary container label the same as primary packaging?
No, a primary container label is not the same as primary packaging. “Primary packaging” and “secondary packaging” are terms used in industries such as pharmaceuticals and food. Primary and secondary container labels are chemical hazard labels under OSHA’s Hazard Communication Standard. The terms sound alike but come from different regulations, so check which one a customer, auditor or colleague means.
Is a secondary container the same as secondary containment?
No, a secondary container is not the same as secondary containment. Secondary containment is a spill-control measure, such as a tray, berm or spill pallet that catches leaks. A secondary container is the container a chemical is transferred into for use. A secondary container stored on a spill pallet still needs its own label.
Can I use NFPA or HMIS labels on secondary containers?
Yes, you can use NFPA or HMIS labels on secondary containers, when employees are trained on the system and SDSs are readily available. They cannot replace the primary label on a shipped container. NFPA and HMIS use numeric ratings that do not map directly to GHS hazard categories, so training should explain the difference. See GHS labels vs NFPA labels.
Do secondary container labels need to be in English?
Yes, secondary container labels need to be in English. Other languages may be added alongside English, which is common in workplaces with Spanish-speaking employees. A bilingual label still has to keep all required information legible, so make sure the second language doesn’t crowd the English text.
Arysha Alif Khan
Arysha Alif Khan is an EHS and chemical safety specialist with a background in biochemistry, biotechnology, and public health. She works closely with the product and regulatory teams to turn complex chemical regulations, SDS requirements, and workplace safety standards into clear, practical guidance for people.