Frequently asked questions and answers in chemical safety

Safety data sheets (SDSs) are essential communication tools in the supply chain. They help everyone concerned fulfil their obligations to manage the risks arising from the use of substances and mixtures.

Read more about the purpose of a safety data sheet.

The REACH Regulation specifies when a safety data sheet must be provided and when it must be supplied on request. In defined circumstances, an SDS does not have to be prepared or supplied to customers.

See the conditions under which an SDS must be supplied.

REACH requires the SDS to be prepared by a competent person with appropriate training. A specific professional licence is not prescribed for SDS compilation or SDS translation, but the supplier remains responsible for compliance.

The SDS is a key source of information about a chemical product throughout the supply chain. The product label must also be based on reliable classification and product information consistent with the SDS.

SDS translation is a specialised process, and even the use of SDS authoring software does not automatically ensure a compliant result.

See the current SDS content and format requirements.

Making an SDS available for download on a company website does not, by itself, demonstrate that it has been provided to the recipient as required by REACH. The supplier should actively provide the SDS, electronically or on paper, and retain appropriate evidence that it was supplied.

Where an SDS is required, it must be supplied in an official language of the Member State where the substance or mixture is placed on the market, unless that Member State provides otherwise. Check the language requirements for safety data sheets in the destination country.

If an SDS is not legally required but the supplier voluntarily provides one in another language, it may still be useful as a source of safety information. Where an SDS is required for a product used at your own industrial site, ensure that the appropriate language version is available to workers. Assess labelling obligations separately in light of the product’s use and how it is supplied.

Employees’ language skills do not replace the language requirements of REACH. The SDS must be available in the required language of the relevant Member State, unless that country allows otherwise. Workers and people responding to an emergency must also be able to access and understand the information they need.

Make the current SDS readily accessible wherever the product is used. Check any separate national requirements for workplace information and labelling.

A supplier may provide SDSs electronically. At the place of work, ensure that workers and emergency responders can readily access the relevant, current information. A printed copy is one practical option; reliable electronic access may also be suitable, subject to applicable workplace requirements.

Finished cosmetic products intended for the final user are generally outside the REACH SDS supply requirements and the CLP labelling rules that apply to chemical mixtures. Their packaging and labelling are instead subject to the applicable cosmetics legislation, including Regulation (EC) No 1223/2009. Check the product’s precise regulatory status before deciding which documents and label elements it needs.

As a distributor reselling a product without changing it, you should at least review whether the SDS is complete and current, and whether its information matches the product label. Check that the label meets the applicable CLP labelling requirements. If you identify an inconsistency or receive new hazard information, contact the supplier.

• Does the label match the product identification and hazard information in the SDS?
• Are the applicable CLP label elements present?

Where you introduce a product into a new Member State, also establish who will provide the SDS in the required language and whether the market’s PCN and UFI requirements are covered. An importer has additional duties. A downstream user formulating a mixture needs reliable information from raw material SDSs to classify the new mixture and prepare its own SDS.

Choose suppliers who can substantiate the accuracy and regulatory status of the source SDS.

Safety data sheets have no fixed expiry date. Their continued validity depends on whether their content meets current requirements and accurately describes the product.

Review and update an SDS when new significant information on hazards or risk management becomes available, when an authorisation or restriction changes, or when other relevant regulatory or product changes require an update. See our SDS revision and update service.

An SDS may need review because the applicable content or format requirements change. A new version of the supplier’s source SDS, a significant change in composition, or new hazard information may also require changes to classification and risk management measures.

Our revision service checks and, where necessary, updates the document against the relevant requirements in force when the work is performed.

When a supplier provides an SDS only in another language, a literal translation is often insufficient. Legal references and country-specific information in the source document may not apply in the destination country.

The wording of certain SDS elements is prescribed, including section headings, hazard statements (H statements) and precautionary statements (P statements). Translation with expert review and localization includes checking the source and adapting the relevant information to EU and destination-country requirements.

Our review includes, as relevant:

• checking component and mixture classifications against CLP;
• adding applicable occupational exposure limits;
• checking transport information; and
• checking and, where necessary, correcting hazard statements and precautionary statements.

We also review the SDS against the applicable EU and destination-country requirements for its content and format.

Check the product’s classification, intended users and packaging. For products supplied to the general public, Section 3.2 of Annex II to Regulation (EC) No 1272/2008 (CLP) specifies when a tactile warning of danger is required. Where the criteria apply, the packaging must carry the warning in accordance with those rules; the SDS indication should agree with the product’s actual labelling obligations.

Under Regulation (EC) No 648/2004 on detergents, applicable in September 2026, detergent packaging must provide the website address where the ingredient list described in Annex VII, Section D, can be accessed. For detergents intended for industrial or institutional use and not made available to the general public, equivalent information may instead be supplied through technical data sheets, SDSs or another appropriate method, where the regulatory conditions are met.

The GHS07 pictogram does not determine this obligation. Assess it under the detergents rules and the product’s intended supply and use. Regulation (EU) 2026/405 establishes a replacement framework that generally applies from 23 September 2029.

Ethanol has a harmonised classification as a flammable liquid under the CLP Regulation. A carcinogenicity classification is not part of that harmonised entry as of September 2026. Any other applicable hazard classification must be assessed using the available evidence and the substance as supplied, including relevant impurities.

Proposals or assessments concerning ethanol’s possible health effects do not, by themselves, change its legally applicable harmonised classification. Where a harmonised entry is amended, the amendment and its application date must be checked in the CLP Regulation. Impurities such as acetaldehyde must be considered where they affect the classification of a particular product.

For questions about an individual substance or regulatory procedure, contact the relevant national REACH or CLP helpdesk in the Member State concerned.

If you place a hazardous substance or mixture on the market, its packaging must be labelled in accordance with the applicable requirements. Based on the SDS and the product information supplied, we determine the mandatory chemical safety label elements and provide an editable Word CLP label draft.

The unique formula identifier (UFI) is a 16-character code that links a mixture to information submitted for emergency health response. For mixtures within the scope of the rules, it is an element of the harmonised Poison Centre Notification (PCN) and is generally displayed on the label, subject to the applicable exceptions.

Importers and downstream users are primary PCN duty holders; distributors may also have duties, depending on whether they relabel or rebrand the mixture, the trade names they use and the Member States in which they supply it. A reseller should check whether the relevant notification covers the destination market. If a label is damaged or a formulation change requires a new UFI, the label must be corrected before further supply.

First identify your role in the supply chain and each Member State where you place the mixture on the market. Then assess whether it is classified for a human health or physical hazard under CLP. Mixtures classified only for environmental hazards are generally outside the scope of the harmonised PCN requirement. Also check any exemptions and special provisions.

A distributor should establish whether the existing notification covers its intended trade name, UFI and destination Member State, and whether it must provide missing information. See our guide to Poison Centre Notification submissions.

The harmonised format was introduced in stages: 1 January 2021 for consumer and professional use mixtures and 1 January 2024 for industrial use mixtures. The transitional period for certain mixtures previously notified under national systems ended on 1 January 2025.

Depending on the mixture and the submission type, gather the following:

• the submitter’s details and an appropriate contact for follow-up requests;
• the product’s trade name or names and its UFI;
• its intended use category: consumer, professional or industrial;
• the submission type, such as an initial submission;
• its product category under the European Product Categorisation System (EuPCS);
• the Member State or States concerned and the required submission language;
• packaging types and sizes, where relevant;
• the full composition, component identities and applicable concentration information: the components generally need to account for the entire mixture, and SDS Section 3 alone is usually insufficient;
• the CLP classifications of the components and of the mixture, including the relevant H statements;
• the applicable label elements;
• the mixture’s SDS, where required or relevant;
• toxicological information, consistent with SDS Section 11; and
• the mixture’s pH, colour and physical state, or a justification where pH cannot be provided.

No. Generating a UFI does not submit the mixture information to the appointed body. Where a PCN is required, the appropriate notification must also be submitted and must cover the mixture, its UFI, trade name and relevant Member State before it is placed on the market. Our PCN notification and UFI management service can assist with these steps.

For a voluntary notification of a mixture that is outside the mandatory PCN scope, displaying the generated UFI on the label is generally optional. Check the mixture’s actual classification and any other applicable requirements before finalising the label.

Potentially yes. Importing a mixture from outside the EU/EEA is placing it on the market for CLP purposes. Where the imported raw material is classified for a human health or physical hazard and falls within the PCN scope, the EU/EEA importer may need to submit a notification for that imported mixture in the Member State where it is brought in and used. Notifying the finished mixture does not automatically cover the imported raw material.

We send a service-specific data request form with our quotation. It asks for information needed for the notification that is usually not available from the SDS alone. We also need an SDS that complies with the requirements in force when the PCN is submitted.

The answer depends on the product and what your company does with it. The same company may resell one product unchanged, introduce another into a Member State, import a third from outside the EU/EEA, and formulate a mixture from a fourth.

Under REACH and CLP, an importer brings a substance or mixture into the EU/EEA from outside it. Buying from a supplier within the EU/EEA does not, by itself, make you an importer.

Check whether you resell, refill or repackage the product; formulate a new mixture; change its trade name or label; or supply it in a new Member State. The resulting SDS, label, UFI, PCN and supply-chain communication duties can differ by product and activity.

A reseller supplies a product already available in that Member State under the relevant trade name and supply arrangement. A company introducing a product into a new national market must check whether the appropriate SDS language, label information and, where applicable, PCN coverage are in place before supplying it.

Resellers must still pass on required safety information, keep labels compliant and check whether any new trade name or destination market requires action. See our overview of distributing chemical products.

A distributor may take on downstream-user duties when it actually uses a substance or mixture in an industrial or professional activity, for example by formulating a new mixture or refilling a product into other containers. Merely reselling, storing, relabelling or rebranding an unchanged mixture does not automatically make the company a downstream user under REACH, although relabelling or rebranding can create separate CLP and PCN duties.

For each activity, check whether the SDS, label, UFI and notification still cover the product and its intended market. Read more about downstream-user communication obligations.

REACH requires the supplier to provide an SDS in the required official language of the Member State where the substance or mixture is placed on the market, unless that Member State provides otherwise. The roles of each supplier and distributor in the chain, and where the product is first supplied, determine who must arrange the language version. If only a foreign-language SDS is available, a professionally reviewed translation and any necessary destination-country adaptation may be required before supply.

A translated SDS is not necessarily accurate or compliant. Check it against the source document and the product’s classification, label, intended use and applicable national details, especially if you will use it for distribution or a PCN submission. Supplier SDSs may contain translation errors, outdated legal references, missing national information or inconsistencies. Read more about checking an SDS received from a supplier.

The harmonised PCN rules cover mixtures placed on the market and classified as hazardous on the basis of health or physical effects. Importers and downstream users have primary submission obligations. Distributors may also have duties, particularly when relabelling, rebranding or supplying in a Member State not covered by the upstream submission. Confirm whether the information available to the relevant appointed body covers the mixture, UFI, trade name and destination market.

Generating a UFI alone does not fulfil a PCN obligation. A mixture classified only for environmental hazards is generally outside this harmonised notification scope.

If agents in a multi-level marketing (MLM) network operate as independent businesses, their own activities may give rise to distributor obligations. Identify the legal entity placing the product on the market in each Member State and establish who must provide the SDS in the required language, ensure the correct label and arrange any notification. The answer depends on the actual supply chain and contractual roles.

An agent acting only as an employee does not ordinarily have separate company-level duties for placing the product on the market; those duties rest with the relevant business.

No. Review the documents and notification when the source SDS, composition, classification, label, UFI, legal requirements or destination market changes. Keep the SDS, label and PCN data consistent with one another and with how the product is actually supplied.

First check which documents you already have. If the supplier provided an SDS in another language, ask about translation with expert review and localization. If an SDS is already available in the target language but you are unsure whether it is accurate or current, request a revision. For a new product without a suitable source SDS, ask about SDS compilation; this requires reliable information on the product and its ingredients.

Our customer service team can help you choose the appropriate service.

SDS compilation is a multistep process in which we prepare a product SDS from the available technical information in accordance with applicable requirements. It is commonly requested by manufacturers, mixture formulators and importers when no suitable SDS is available.

We need the product’s trade name, full and accurate composition, relevant raw material SDSs, and available information about the product and its ingredients. We confirm the complete list of required documents during ordering.

If the supplier provides an SDS only in another language, we translate it and check its technical content. A word-for-word translation may reproduce references or data that apply only in the source country.

Some SDS text follows prescribed regulatory wording, including section names, hazard statements (H statements) and precautionary statements (P statements). Expert review and localization also address errors or omissions in the source SDS, as needed.

• We check component classifications and the mixture classification under CLP.
• We add missing applicable occupational exposure limits.
• We review transport information.
• We check and, if necessary, correct the hazard and precautionary statements.

We assess the document against the relevant EU and destination-country rules for SDS content and format.

An SDS may require revision if its prescribed content or format changes, a revised source SDS becomes available, the product composition changes substantially, or new hazard information affects classification or risk management measures.

Our review identifies the necessary changes and produces a revised document aligned with the requirements in force when it is prepared. For subsequent monitoring, ask about our SDS Control service.

Hazardous substances and mixtures placed on the market must have the applicable label elements. We review the SDS and information provided, determine the chemical safety information required for the product label, and supply an editable Word draft. Final packaging artwork and any sector-specific labelling requirements should be checked separately.

Our quotation includes a service-specific data request form for information not normally available in the SDS, including the full composition, use category and packaging details where applicable. We also need an SDS that meets the relevant requirements at the time of submission.

We recommend using the online quotation form for SDS services. If you prefer to write to us, use the email address on our customer service page. We aim to respond to quotation requests within 24 hours. For an urgent request, please also call customer service.

Tell us which service you need and how many products are involved. If you need a translation or revision and already have the source documents, attach them to your request to help us prepare a prompt and accurate quotation.

Every quotation issued by ToxInfo states its validity period. If it expires, we can issue an updated quotation with a new reference number; the delivery date may change.

If you accept our quotation, confirm your order with customer service by email or telephone. You may also use your company’s own purchase order system and refer to our quotation number. The accepted quotation and applicable terms govern the individual assignment.

After confirming the order, we review the documents you have sent. If essential information is missing or inconsistent, your contact person will tell you what else is required.

Occasionally, an issue becomes apparent only during expert review. In that case, your contact person or an expert will contact you to resolve it, and the confirmed delivery date may need to change.

Yes. The information required may differ from product to product, including trade names and intended uses, so a form completed for an earlier order is not a substitute for the current order’s product data.

There is no fixed upper limit. We may offer a quantity-based discount depending on the number of documents. For larger volumes, ask about the MSDS-Europe Customer Support Program.

We prefer editable Word files or PDF files without access restrictions.

If you need an SDS urgently, ask about our Rapid service, with a turnaround of 72 hours where available. A shorter Express option may be available for a limited number of documents by prior agreement. Capacity, complete source data, weekends and public holidays affect the possible delivery date.

We confirm availability, scope, price and deadline before accepting an urgent order. For the quickest response, please contact customer service by telephone.

The standard lead time is normally 8–10 working days after we receive the information needed to start the work. Ask about priority service if you have a shorter deadline. Your order confirmation states the agreed delivery date.

Delivery also depends on the agreed payment terms and the information needed to complete the work. If a pro forma invoice applies, we release the completed documents after payment is received. We notify you when the order is complete and, where appropriate, ask you to check whether payment has been made.

Clients with a contractual arrangement may be eligible for payment after delivery. Include your order reference number with the payment so we can identify it.

Our SDSs use a consistent professional layout. If your company requires different branding or colours, we can discuss those requirements before preparing the document.

Yes. Please complete the relevant part of the order form and send us a JPEG version of your logo at a suitable resolution.

We provide a full professional and financial guarantee for the safety data sheets we prepare. Our financial guarantee covers direct and indirect damage. Our customer service team responds to comments within 24 hours.

We offer quantity-based discounts for multiple documents; the rate is specified in the quotation. For translations, the quantity discount applies to documents ordered for the same target language.

Not in every case. We generally use a pro forma invoice, with payment due under the terms stated in your order confirmation. Contractual clients may be eligible for payment against a final invoice.

Yes. After payment and completion of the service, we send the final invoice electronically. If you need a paper copy, please let us know. The applicable tax treatment depends on the transaction and your company’s details.