Dear Chris
I am not sure if I understood your issue. In DG Filling we have to differentiate two phrase sections.
On phrase section is generated automatic (e.g. the "Hazard inducer" is maintained as an identifier and will get a phrase) and those fields there you don't use a "phrase" generation but you have a phrase set attached to it as part of the DG master.
In the automatic part of phrase generation (if I remember correct) you need to make sure (if i remember correct) that you have a "regulartory list" assigned to the identifier to make it happen and clearly if you maintain only an identifier in "DE" the phrase generation can only generate "DE" as the phrase position.
In contrast to e.g. MSDS distribution process there is no OSS consulting note available regarding DG topics.
May be check again: http://help.sap.com/erp2005_ehp_07/helpdata/en/3e/6095750d1311d286e7080009b98822/content.htm?frameset=/en/de/5174db4c4b11d18a110000e816ae6e/frameset.htm
Subchapter "Phrase Generation in Filling"
The topic is not easy to understand
C.B.
PS: only for completeness: sometimes there are some "errors" in the process e.g.: DG filling: Phrase for hazard note is not found
PPS: may be check: http://scn.sap.com/thread/3429385