EuPCS and Identified Uses in the Safety Data Sheet and in PCN Notifications

MSDS-Europe – Safety Data Sheet knowledge base – EuPCS and identified uses

Introduction: EuPCS (European Product Categorisation System) and the “relevant identified uses” listed in SDS Section 1.2 may seem like two separate topics at first glance: one is required for product categorisation in a PCN notification, while the other records what the product is used for and by whom in practice. In reality, they are closely linked—because both answer the same practical question: what the product is intended for, and in what use setting it appears.

In this article, we provide a clear overview of what SDS Section 1.2 should contain, when it is necessary to specify uses advised against, how this aligns with the logic of CSR/ES, and why it is worth treating EuPCS “in one system” together with use-related information.

Why is the information in Section 1.2 important?

SDS Section 1.2 is the part that quickly helps the recipient understand the typical intended purposes of the product, and whether there are any uses that are particularly risky or not recommended.

SDS Section 1.2 is good practice if it:

reduces risks arising from incorrect use,
supports workplace risk assessment,
helps downstream users (e.g., mixture formulators) select appropriate risk management measures,
and links “product use” to the CSR/ES logic where relevant.

What does the legislation say? (EU 2020/878 – REACH Annex II)

REACH Annex II was amended by (EU) 2020/878; this regulation sets the content and format elements of a safety data sheet.

Key logic for Section 1.2:

At least a brief description of the relevant identified use(s) must be provided (e.g., floor cleaning; industrial use in polymer production; professional use in cleaning agents).
Uses advised against and the reasons must be stated “where applicable”.
Where CSR and ES are required, the information in Section 1.2 must be consistent with the identified uses in the CSR and with the exposure scenarios set out in the annex to the SDS.

Identified uses: what is worth including?

1) Specify “who” the use is for and “what” it is for

Typical recipients of Section 1.2 include:

industrial users (sites),
professional users (e.g., cleaning, maintenance),
consumer uses (only if relevant and legally appropriate).

The description should be brief but unambiguous: use area + user group.

Examples:

“Industrial use: as a solvent for surface treatment in a closed system.”
“Professional use: as a component of a degreasing cleaner, diluted.”
“Laboratory use: for analytical purposes, in small quantities.”

2) Briefly indicate the “use boundaries”

Section 1.2 is not meant to replace the details of Sections 7–8; however, it is helpful to indicate—briefly—key boundaries implied by the nature of the use:

closed vs. open process,
whether aerosol formation is expected,
whether spraying or dust formation may occur.

If an exposure scenario exists, these boundaries will be described in detail there, and Section 1.2 should match that logic.

3) Be consistent with supplier information

This is particularly important for mixtures: the mixture supplier extracts the relevant information from the exposure scenarios of the raw materials and forwards it consistently in their own SDS (adapted to the actual conditions of use).

Uses advised against: when and how should they be stated?

Uses advised against are “live” information if the supplier is aware of a use that:

creates a disproportionate risk due to the hazardous properties,
requires risk management measures that are not realistically maintainable,
or is not covered by the ES/CSR (i.e., safe use is not demonstrated).

Good practice: do not only prohibit—give a reason.

Example:

“Not recommended: spray application outside an industrial setting – control of inhalation exposure cannot be ensured.”

This does not have to be an “endless list”, but it is worth naming the real, foreseeable risks in a targeted way.

Link to the CSR and exposure scenarios (ES)

When are CSR and ES mandatory?

Above certain tonnage thresholds and under specific hazard conditions, a chemical safety report is required, and an exposure scenario is prepared for each identified use.

What does “consistency” mean in Section 1.2?

In practice, it means:

do not include a use in Section 1.2 that is not assessed in the CSR/ES,
and conversely: do not omit the CSR/ES “main” uses from Section 1.2.

EuPCS: what is it, and why is it often mentioned together with product use?

EuPCS (European Product Categorisation System) is an ECHA-maintained product categorisation system used in PCN notifications to categorise mixtures. In practice, EuPCS selection is typically handled together with other PCN inputs (e.g., UFI management and submission), which is why it is commonly discussed alongside product use information (see our PCN notification services and UFI management).

Key difference:

SDS Section 1.2 describes uses (what it is used for),
EuPCS is a product category in the PCN dossier (what “type” of product it is).

Still, they are often managed together because both answer the same real-life question: “What is this product, and how is it used in practice?”

European Product Categorisation System (EuPCS) – download

FAQ – SDS Section 1.2 (identified uses and uses advised against)

Is one sentence enough for identified uses?

Yes—the minimum expectation is a short, clear description. However, if multiple target groups apply (industrial/professional/consumer), it is worth splitting the text into 2–4 short lines.

Is it mandatory to list every possible use?

No. The goal is to name the relevant uses. Under the regulation, an exhaustive list is not required for uses advised against either.

When should uses advised against be stated?

When the supplier does not recommend a certain use and a clear reason can be given (e.g., high inhalation risk, exposure cannot be controlled, or the use is not covered by the ES/CSR).

Do mixtures also need CSR/ES consistency?

CSR/ES are typically prepared for substances, but for mixtures, relevant elements from supplier exposure scenarios should be handled consistently in the mixture’s SDS.

Must EuPCS be included in the SDS?

EuPCS is primarily part of the PCN (Poison Centre Notification) dossier, not a mandatory SDS element. However, it supports understanding the product’s practical intended use, so in company documentation it is often managed together with use information.

Summary

What should you focus on when drafting SDS Section 1.2?

Name the identified uses briefly and in a targeted manner.
If applicable, list uses advised against with a short justification.
Where CSR/ES apply, ensure consistency between Section 1.2, the CSR, and the exposure scenario annexes.
EuPCS (PCN) and SDS Section 1.2 serve different purposes, but together they make the product’s intended use truly clear.

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