Useful background information for downstream users on safety data sheets.

Safety data sheet knowledge base – About the safety data sheet for downstream users

The safety data sheet as a communication tool

Safety data sheets are important communication tools in the supply chain. They help all members of the supply chain meet their responsibilities related to the management of risks arising from the use of substances and mixtures.

Downstream users are informed—via the safety data sheet—about the risks arising from their identified use and about the risk management measures required to control these risks.

Exposure scenario

Some safety data sheets also include an annex called an exposure scenario. The exposure scenario provides more detailed information on safe use and on reducing exposure than the main safety data sheet.

If the exposure scenario does not cover the intended use, you should contact the supplier. Otherwise, downstream users should prepare their own chemical safety report.

Tasks to do if you do not get a safety data sheet for the purchased substance/mixture

This does not mean that you do not have to implement—and communicate to other members of the supply chain—the risk management measures that the supplier discloses by other means (e.g. in a written statement, on a technical data sheet, in specifications, etc.).

Not receiving a safety data sheet may indicate that the substance or mixture is not considered hazardous.

Nevertheless, you should contact the supplier and request a safety data sheet (in some cases, legislation allows suppliers to provide a safety data sheet only upon request).

Tasks to do after receiving a safety data sheet

You should check whether the safety data sheet contains a REACH registration number.

If a REACH registration number is included in the safety data sheet, you have 12 months to comply with the REACH obligations applicable to downstream users.

If a substance has not yet been registered and no REACH registration number is provided, you should follow the instructions given in the safety data sheet.

You should check the information on hazards and on risk management measures. You should also verify the implementation of the risk management measures and whether any substance—either on its own or as part of a mixture—is subject to authorisation or restrictions.

If the supplier does not support certain uses in order to protect human health or the environment, they must indicate this in Section 16 of the safety data sheet or among the information provided in compliance with Article 32. If the recommendation against a use is not justified, the downstream user has the right to request further information or justification.

Tasks to do in case of uses advised against

• You should stop using the substance or mixture for that use.
• Safe use can be demonstrated by preparing a downstream user chemical safety report. For this purpose, you should evaluate the use of the substance or mixture in more depth than the supplier and, where appropriate, modify the conditions of use.

Tasks of downstream users producing mixtures regarding safety data sheets

After the hazard classification has been carried out, you can determine whether you must provide a safety data sheet to your customers for the mixture.

A safety data sheet must be provided for professional use in the following cases

• If a substance or mixture is classified as hazardous
• If a substance is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII
• If a substance is included in the candidate list (the list established in accordance with Article 59(1))

If the mixture does not qualify as hazardous, the customer may request the safety data sheet in the following cases

• It contains a hazardous substance at a concentration of ≥ 1% by weight for non-gaseous mixtures.
• It contains a hazardous substance at a concentration of ≥ 0.2% by volume for gaseous mixtures.
• It contains at least one substance present at an individual concentration of ≥ 0.1% by weight for non-gaseous mixtures that is carcinogenic category 2, toxic to reproduction category 1A, 1B or 2, skin sensitiser category 1, respiratory sensitiser category 1, has effects on or via lactation, or is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII.
• It contains a substance that is included in the candidate list (the list established in accordance with Article 59(1)).
• It contains a substance for which occupational exposure limits have been established at EU level.

If none of the above conditions is met—so a safety data sheet does not have to be provided for the substance or mixture—suppliers must provide the following information to all their downstream users and distributors (Article 32 of REACH):

• If the substance is subject to authorisation, details of the authorisation granted or—if authorisation is refused—appropriate information on the applicable restrictions.
• Any relevant information about the substance that is necessary to enable appropriate risk management measures to be identified and applied.
• The REACH registration number(s), if available, for any substances for which information is communicated under the points above.

A safety data sheet does not have to be provided for hazardous substances or mixtures offered to the general public where sufficient information is provided to allow users to take the necessary measures to protect human health, safety and the environment, unless a downstream user or a distributor requests it.

You can find our article on the content and format elements of a safety data sheet here.

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