6 Smart Ways to Tackle Small Container Labeling Under GHS Rev. 7

Small container labeling hasn’t necessarily gotten harder under OSHA’s updated alignment with GHS Revision 7, but it has gotten a lot more specific. For safety professionals and operations teams, the update means rethinking how you handle limited label space while still checking every compliance box.

You’re working with stricter formatting, clearer labeling tiers, and tighter requirements for what must appear on the container and when. Even tiny containers, as small as 3 mL, have new rules to navigate. This article breaks down what’s different under GHS Rev. 7, why it matters, and how you can adjust your labeling strategy without missing a beat.

The Update at a Glance: What Changed Under GHS Rev. 7

In May 2024, OSHA finalized updates to the HCS, aligning it with the UN’s GHS Revision 7. The changes went into effect on July 19, 2024, with deadlines for full compliance starting January 19, 2026, for substances and July 19, 2027, for mixtures.

Here’s what matters for small containers:

🔹Containers up to 100 mL: Can use abbreviated labels if space is limited. These labels must include:

• Product identifier
  

• Appropriate pictogram(s)
  

• Signal word
  

• Manufacturer’s name and phone number
  

• Full label must still appear on the outer package.

🔹Containers up to 3 mL: If even abbreviated labels prevent safe use, only the product identifier is required, as long as the full label appears on the outer packaging.

These rules apply to chemical manufacturers, importers, distributors, and employers using hazardous chemicals. That’s a wide net, and it pulls in everyone from global suppliers to shop-floor safety leads. Of course, understanding the rules is just one part of the challenge. Applying them to real-world operations, especially in high-volume or fast-paced environments, is where many teams start to feel the strain.

The Challenges of Small Container Labeling

Labeling something the size of a nail polish bottle with critical safety info isn’t easy. Here’s what companies are running into:

• Space limitations make it impossible to include full hazard information.
  

• Inconsistent labeling across different product lines creates confusion for workers.
  

• Manual fixes, like fold-out labels or tags, are time-consuming and prone to error.
  

• Lack of visibility across departments leads to outdated or incorrect labels in circulation.
  

• Compliance risks increase when labeling workflows rely on human memory or outdated spreadsheets.

In many organizations, EHS managers are stuck between wanting to update everything at once and not having the bandwidth to keep pace with each regulatory change. But the good news is, these challenges can be managed. With a clear plan and the right tools, your team can handle small container labeling without falling behind or adding complexity.

Best Practices for Staying Compliant Without Disruption

If you’re handling small containers and want to avoid disruptions or penalties, these best practices can help.

1. Know what must go on the label

For containers holding 100 milliliters or less, OSHA keeps it simple, but mandatory. Labels must include:

• The product identifier
  

• A pictogram showing the hazard
  

• The signal word (like “Warning” or “Danger”)
  

• Manufacturer’s name and phone number
  

A practical way to avoid mistakes is to lock down a master label template with these four items pre-populated. Then build automation rules that pull product-specific data into place. That way, even your smallest vials meet the standard every time.

2. Don’t forget the outer packaging

Every small container must ship or store inside a fully labeled secondary package. It’s about protecting downstream users, like warehouse staff or subcontractors, who might only interact with the bulk packaging.

If your business relies on third-party shippers or warehouses, share your labeling expectations upfront. Miscommunication often happens here, especially when the full label is applied after a product leaves your facility.

3. Use tag or fold-out labels only when necessary

These labeling tools work, but they slow things down. Fold-outs may interfere with labeling machines or peel off in damp environments. Tags can get separated from the container, especially in high-touch settings like field kits or lab benches.

If you must use them, consider reserving them for high-risk materials where abbreviated labels don’t capture enough information. Also, log each use in your EHS system to track which containers are using which labeling method.

4. Match labels to SDSs

It only takes one outdated SDS to create a ripple effect across your entire labeling program. Label content should always match the latest classification and hazard information in your Safety Data Sheets.

Some companies assign this responsibility to procurement, but if updates aren’t pushed out to production or EHS teams, errors follow. A stronger method is linking your SDS database directly to your label generation system. When SDS data changes, the label updates automatically.

5. Train your team

Labeling isn’t just an EHS job, it’s a shared responsibility across purchasing, inventory, shipping, and safety. Everyone touching the product should know what a compliant label looks like and what to do if something is missing or unclear.

Short, role-specific training modules help here. For example, warehouse staff may need five minutes on how to recognize noncompliant packaging, while safety leads may need a refresher on interpreting pictograms. Refresh training regularly and tie it to performance audits so it becomes part of your compliance culture.

6. Keep label templates standardized

Standardize your template structure across similar products and container sizes. This creates consistency for employees and reduces labeling delays when new products are introduced. Build templates with OSHA’s rules already baked in, like character limits, pictogram sizing, and minimum font sizes, so the labels stay readable and accurate.

Even with best practices in place, managing labels across dozens, or even hundreds, of container types can quickly become overwhelming. That’s where HSI comes in.

How HSI Helps: Smarter Labeling with Less Hassle

Staying compliant with small container labeling doesn’t have to be a manual, time-consuming task. HSI’s Chemical Management software takes the pressure off your team by automating the process and helping you stay in step with every regulatory change.

Here’s how we make it easier:

• Labels That Practically Build Themselves: HSI’s EHS System pulls directly from your SDS library to generate ready-to-use labels. Whether you're labeling a 5-gallon drum or a 3 mL vial, the formatting adjusts automatically to fit the container without sacrificing compliance.

• Built-In Compliance Intelligence: No need to second-guess which pictogram or signal word applies. The software uses your chemical classification data to auto-populate every required field, including hazard statements and manufacturer information.

• One Update. System-Wide Impact: Change a product, update an SDS, or adapt to new OSHA rules, HSI updates every linked label in your system, automatically. That means less room for error, fewer duplicate efforts, and real-time consistency across the board.

• Proactive Compliance Monitoring: The system flags outdated or missing labels before they become a problem. You’ll know exactly where your labeling stands at any time, without digging through spreadsheets or cross-checking files.

Labeling doesn’t have to slow you down. With HSI, you can manage small container labeling with the same confidence and control as your largest shipments. Let us show you how. Book a demo today and see how HSI can simplify your labeling process, reduce risk, and help you stay ahead of every regulatory deadline, without adding extra work to your team.