SDS, MSDS, HDS, and many other acronyms are commonly used to refer to Safety Data Sheets (SDSs)—documents that can be challenging to prepare but provide essential information for anyone handling chemical products safely.
Perhaps the most widely used acronym is SDS, which stands for Safety Data Sheet. But what exactly is an SDS, when is it required, and what information does it contain?
A Safety Data Sheet is the document used to communicate information about a chemical product throughout the supply chain.
An SDS contains information on a product’s hazards, composition, recommended personal protective equipment (PPE), and many other key details needed to ensure the safe handling and use of chemical products.
The structure and content of SDSs are internationally harmonised, although specific requirements may vary slightly depending on the legislation of each country. In the European Union, Safety Data Sheets are regulated under the REACH Regulation (EC) No 1907/2006.
Under REACH, companies placing chemical products on the European market must understand and communicate the hazards and risks associated with their use.
A chemical product (substance or mixture) must be accompanied by a Safety Data Sheet if:
The correct application of this criterion requires specialised CLP classification and labelling expertise.
However, there are also exemptions to this requirement. One of the most common is that Safety Data Sheets are not required for finished products intended for end users when they are:
However, caution is required. If the mixture is supplied for use in the formulation of other mixtures or simply for repackaging, an SDS may still be required.
1. A company supplies bulk perfume to another company that repackages it into smaller containers for sale.
The company is required to provide the repackager with an SDS for the bulk perfume. The repackager will be exposed to the product in larger quantities and therefore needs to understand the risks associated with these activities. This information can be found in the product’s SDS.
2. A company supplies small perfume bottles ready for consumer use.
In this case, an SDS is generally not required because the product is marketed solely as a cosmetic product and the relevant information is provided under cosmetics legislation.
For articles, providing an SDS is generally not required. However, some companies still use SDS-like formats to communicate safety information to customers, although this is not always the most appropriate approach.
You can find more information about the obligations that apply to companies placing articles on the market here.
In Europe, the structure and content of SDSs are defined in Annex II of REACH.
This annex has been amended several times, with the latest version introduced through Regulation (EU) 2020/878.
An SDS generally consists of 16 sections and, where applicable, an Annex containing Exposure Scenarios.
Structure of an SDS
Safety Data Sheets must be prepared by individuals with sufficient training and expertise to complete all required sections accurately.
In practice, it is uncommon for a single person to possess detailed knowledge covering all 16 sections. As a result, companies often involve several specialists or outsource SDS preparation to regulatory consultants such as ServiREACH.
Companies managing large portfolios of chemical products frequently use specialised SDS authoring software. However, such software is intended to streamline the process and does not replace the need for competent and trained personnel.
An SDS must be supplied in the official language(s) of the country where the product is being marketed.
The REACH Regulation does not establish a validity period for Safety Data Sheets. However, it does require SDSs to be updated without delay whenever new information becomes available that affects the product’s hazard classification, risk management measures, or other relevant aspects. In other words, an SDS must be updated whenever changes occur that render the information it contains inaccurate or no longer up to date.
Some of the circumstances that may require an SDS to be updated include changes to the hazard classification of one of the mixture components, the recent REACH registration of a substance contained in the mixture, new test results demonstrating that the product is no longer corrosive, regulatory amendments, and other similar developments.
The publication of Regulation (EU) 2020/878 is one example of a regulatory change that has required companies to update their Safety Data Sheets.
This Regulation replaces Annex II of the REACH Regulation, introducing significant changes to the structure and content of Safety Data Sheets.
Regulation (EU) 2020/878 entered into force on 1 January 2021. However, SDSs prepared in accordance with Regulation (EU) 2015/830 (the previous version of Annex II) remained valid until 31 December 2022. After 31 December 2022, only SDSs compliant with the format requirements of Regulation (EU) 2020/878 are considered valid.
An SDS must be provided free of charge, at the latest when the substance or mixture is supplied for the first time.
The supplier must provide it proactively, either electronically or in paper form, without waiting for the recipient to request it. Updated SDSs must also be supplied free of charge to all recipients who have received the substance or mixture within the previous 12 months.
Companies should be able to demonstrate both the transmission and receipt of these documents in the event of an inspection. For this reason, many organisations use specialised software solutions, such as REACHGallery, to manage SDS distribution and compliance.
If you need support with the preparation, review or updating of Safety Data Sheets, the ServiREACH team can help ensure that your documentation complies with the latest regulatory requirements.
General Manager and Regulatory Affairs Specialist for chemical products. I work with REACH, CLP, and Biocides (BPR) to reduce business risks, accelerate compliance, and facilitate access to the European market.
