For anyone amending a label or registering a new product under Act 36 of 1947. This is information, not legal advice. Checked 26 October 2026.
The short version
The registrar wants hazard information on labels in the Globally Harmonised System (GHS) format. The guideline lists seven documents to send with a label amendment or new application so that it includes the GHS information. That is the GHS package, not the whole of a new registration dossier. For an amendment the guideline applies the minor amendment tariff. For a new registration under the fast-tracking protocol there is no GHS fee.
What goes in the GHS package
- A covering letter that quotes the registration number (the B, K, L or M number).
- The service form.
- The new label.
- Your declaration, in the registrar's format.
- A safety data sheet.
- Proof of payment.
- A classification rationale.
The label
Lay it out the way the registrar's example for your product type does. Keep the content the same as the approved label, except for the GHS changes and the new label elements the guideline says the draft regulations required. The guideline says there shall be no colour band, but see the check below. Include the GHS label elements that your classification requires: pictogram, signal word, hazard statements and precautionary statements. Some products are unclassified, and the examples say so. Do not print the statement codes.
The 2023 regulations add that labels must be in English (other languages are allowed if identical), clearly legible and indelible, and accompanied by information explaining the hazard statements, pictograms and signal words and the behaviour that reduces exposure. That can be a removable leaflet or a QR code. No remedy may be distributed or sold without a label the registrar has approved, so submitting a new label does not by itself let you sell on it.
The declaration
Someone at the company confirms that the label content has not changed apart from GHS. This wording assumes there is an existing approved label, so ask how it applies to a wholly new product. They also confirm that a competent person compiled the GHS information using the latest edition of the UN Purple Book, and that the safety data sheet complies with section 14 of the Regulations for Hazardous Chemical Agents, 2021. The holder also agrees to pay for an independent review of the classification if it is challenged.
The classification rationale
This is the part that needs the most evidence. It must set out the formulation, the classification of every component, and a demonstration that all the hazard classes for which any ingredient is classified were considered. It must say which components you left out of a particular hazard class because their levels are too low to count for that class. It must also show the data, bridging principles or calculations behind your classification, and the classification that results.
Fees
For a label amendment the guideline says the minor amendment tariff applies. It does not give the amount, so check the current tariff regulations. The fast-tracking protocol says there is no GHS classification fee for a new registration under that protocol. That is not a waiver of the registration fee. It also says a label extension that has not yet been updated to GHS pays the relevant tariff, and that no extra payment is due if you already applied to update the label. Confirm which transaction your submission is before you pay.
Check with the registrar
The example layouts in the guideline's annexure still show a colour band on some product types, which conflicts with the statement that the band is gone. The examples are also marked as proposed and internal, and some text in them is unfinished. Do not copy them as they stand. Ask the registrar's office which layout to follow before you print.
The guideline refers to draft regulations. The final Regulations relating to agricultural remedies of 25 August 2023 now say classification and labelling must follow GHS and the Regulations for Hazardous Chemical Agents, 2021 (regulation 15). They make the registration holder responsible for the accuracy of the classification. The registrar may ask for an independent review at the holder's cost. If the classification is found to be wrong, the registrar must require the label to be corrected and may require the product to be withdrawn.
Sources
Guideline on the implementation of the Globally Harmonised System of classification and labelling of chemicals classification, issued by the Registrar of Act 36 of 1947, March 2022. Regulations relating to agricultural remedies, 25 August 2023 (regulations 15 to 17). Protocol for submission of applications for fast-tracking of registrations to replace agricultural remedies identified as substances of concern, November 2023. The guideline is published on the department's guidelines page: https://www.nda.gov.za/index.php/publication/581-guidelines