A Safety Data Sheet (SDS) is a key document in chemical compliance that provides detailed information about a chemical product’s properties, potential hazards, and safety measures.

Companies that manufacture, use, or distribute chemicals require an SDS to ensure the safe handling of their products. The document is primarily intended for professional users, such as employers, safety officers, and regulatory authorities, and helps minimize risks in the workplace.

The requirements for Safety Data Sheets are primarily based on the REACH Regulation (EC) No. 1907/2006 in the European Union. This regulation outlines the necessary content, structure, and update obligations for SDSs in Article 31.

Additionally, the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) sets international standards for hazardous substances. Depending on the target market, national regulations may also impose additional requirements.

The CLP Regulation (EC) No. 1272/2008 (Classification, Labelling, and Packaging) plays a crucial role in the creation of Safety Data Sheets (SDSs) by defining the classification criteria for hazardous substances and mixtures. It ensures that hazards are consistently identified and communicated across the European Union.

The impact of CLP on SDSs includes:

• Harmonized Classification and Labelling: The SDS must include the correct hazard classification according to CLP, using standardized hazard pictograms, signal words, and H- and P-statements.
• Label Drafts: Companies placing hazardous chemicals on the market must create compliant label drafts that align with the information in the SDS, ensuring that packaging and documentation provide clear and legally required hazard communication.
• Notification to the ECHA C&L Inventory: Manufacturers and importers of hazardous substances must notify the European Chemicals Agency (ECHA) of their substance classification and labelling details. This is mandatory for all substances placed on the EU market, even if they are part of a mixture. The C&L Inventory serves as a central database for hazard classifications, helping to ensure consistency in chemical safety information.
•  CLP Amendment VIII and PCNs: The CLP Amendment VIII, which aligns the EU system with the UN's GHS revisions, introduced specific requirements for Product Chemical Notifications (PCNs). These notifications are required for certain chemical products, ensuring that the classification, labelling, and safety data are consistent with updated international standards.

Ensuring compliance with CLP regulations is essential to avoid regulatory penalties and ensure workplace and environmental safety. At CSB Compliance, we support companies in preparing CLP-compliant SDSs, creating correct label drafts, and handling the necessary notifications to the ECHA C&L Inventory.

A Safety Data Sheet is required whenever a chemical product is classified as hazardous and placed on the market. This includes substances and mixtures with physical, health, or environmental hazards. In some cases, an SDS is also needed for non-hazardous chemicals, for example, if they contain certain health- or environment-related components or upon customer request.

Companies that import or use chemicals must ensure they have up-to-date and complete SDSs.

The responsibility for preparing and providing a compliant Safety Data Sheet lies with the manufacturer, importer, or supplier of the chemical product. They must ensure that the SDS meets all legal requirements and is updated as needed.

Distributors are generally not required to create their own Safety Data Sheets as long as they resell products within the EU and do not alter the composition or labelling of the substance or mixture. However, they are obliged to verify that the SDS provided by the manufacturer or importer is complete, accurate, and up to date before forwarding it to their customers.

If a distributor acts as an importer—meaning they place a product from a non-EU country on the European market—they assume the legal responsibility for preparing their own Safety Data Sheet. This SDS can be based on the manufacturer’s version but must be adapted to EU regulations (REACH and CLP).

CSB Compliance assists importers and distributors in meeting these obligations and ensuring that all Safety Data Sheets are compliant with current legal requirements.

An SDS comprises 16 sections with information on hazards, handling, storage, protective measures and emergency procedures.

• Identification of the substance or mixture: Trade name, manufacturer, emergency contact
• Hazard identification: Classification according to GHS, hazard pictograms, H- and P-statements
• Composition/information on ingredients: Chemical composition, hazardous components
• First-aid measures: Procedures for skin contact, ingestion, or inhalation
• Firefighting measures: Suitable extinguishing media and protective actions
• Accidental release measures: Procedures for spills or leaks
• Handling and storage: Safe handling and storage conditions
• Exposure controls/personal protection: Recommendations for respiratory protection, gloves, eye protection
• Physical and chemical properties: pH value, flash point, solubility
• Stability and reactivity: Information on chemical stability and possible reactions
• Toxicological information: Health effects upon exposure
• Ecological information: Impact on water, soil, and air
• Disposal considerations: Guidelines for environmentally friendly disposal
• Transport information: Classification under transport regulations (ADR, IMDG, IATA)
• Regulatory information: National and international legal requirements
• Other information: References and additional notes

A Safety Data Sheet must be available in the official language of the country where the chemical product is placed on the market. Within the EU, this means that an appropriate language version is required for each target country.

If a product is distributed in multiple countries, multilingual documentation may be necessary. Accurate translation is crucial to ensure that all users understand and correctly implement the safety information.

Creating Safety Data Sheets requires in-depth knowledge of chemical regulations, classification criteria, and legal requirements. According to the REACH Regulation, safety data sheets may only be created by qualified persons.

An external service provider like CSB Compliance offers several advantages:

• Legally compliant and up-to-date SDSs: Our experts stay informed about new regulations and ensure that your documents meet all legal requirements.
• Time and cost savings: Instead of using internal resources for the complex creation and updating of SDSs, you can focus on your core business.
• Customized solutions: We offer tailored services and adapt flexibly to special customer requirements.
• Multilingual support: We create SDSs in the required languages and consider country-specific regulations.

With our service, you can be confident that your Safety Data Sheets are not only legally compliant, but also practical and easy to understand.