Safety Data Sheets
The document that carries your classification into the real world.
A fixed structure, in a fixed order.
Every SDS follows the same 16-section structure set out in Annex II, so that anyone reading one, anywhere in the supply chain, knows exactly where to find a given piece of information. Sections cannot be left blank without a stated reason, and each has its own defined sub-headings.
When an SDS needs exposure scenarios attached.
An extended SDS (eSDS) is a standard 16-section SDS with one or more exposure scenarios annexed, as provided for under Article 31(7). It applies where a substance has been registered above 10 tonnes a year and required a Chemical Safety Report — the annexed scenarios set out the operating conditions and risk management measures behind each identified use.
Receiving an eSDS carries its own duty: under Article 37(5), a downstream user has to check whether their actual use is covered by the scenarios annexed. If it is not, the options are to adopt the conditions described, raise the use with the supplier so it can be added to a future version, or prepare a downstream user Chemical Safety Report of their own.
The document is only as good as the data behind it.
Authoring an SDS is not really a writing exercise; it is an exercise in pulling together data that has to be correct before the document is even started. The classification in Section 2 has to match the current CLP classification, the composition in Section 3 has to reflect the actual formulation, and the exposure controls and toxicological information have to be consistent with any Chemical Safety Report and exposure scenarios that sit behind the substance.
Where a substance carries a Chemical Safety Report, an extended SDS (eSDS) with exposure scenarios annexed is required, setting out the conditions of use the risk assessment is based on. Getting an eSDS wrong is one of the more common gaps we find, because the annexed exposure scenarios have to genuinely reflect how the product is used downstream, not a generic template.
A significant share of SDS in circulation would not pass a proper check.
A large proportion of SDS in circulation are not fully compliant. An EU-wide enforcement project run by ECHA’s Forum, checking over 2,500 safety data sheets across 28 EU and EEA countries, found roughly one in three to be non-compliant — and that was among SDS already in active use, not a sample of obviously poor documents.
Assessing an existing SDS portfolio means checking it section by section against the current legal requirements and against the product it actually describes, not just confirming that all 16 headings are present. The most common gaps we find sit in the classification, the exposure controls, and consistency between the SDS and the product label.
An SDS is not filed once and left alone.
Under Article 31(9), specific triggers create a legal duty to update an SDS without delay, and to supply the revised version free of charge to anyone who has received the substance or mixture in the preceding 12 months. Many organisations also review SDS on a rolling schedule regardless of a specific trigger, simply because relying on someone noticing a trigger is not a reliable control on its own.
The same product, but not automatically the same document.
A single EU-format SDS is not automatically valid for the GB market, and vice versa, even where the underlying substance and classification are identical. Selling into both markets means maintaining both versions, and keeping each aligned with its own regime as UK REACH and EU REACH continue to develop on separate tracks.
SDS that actually hold up to scrutiny.
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