Frequently asked questions and answers in chemical safety

MSDS-Europe – Frequently asked questions and answers in chemical safety

Collection of questions and answers in the field of chemical safety. Do you have questions related to chemical safety?

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Questions related to chemical safety

• What is the UFI? Do I have to do anything with it as a distributor?
• I would like to have a safety data sheet and label for cosmetics. What information do I need to provide? Do the requirements of chemical safety also apply to this product group?
• What is the purpose of a safety data sheet?
• Do all chemical products require a safety data sheet?
• Do I always have to have a safety data sheet in the language of the target country, or can I use the safety data sheet in a foreign language (e.g. English) provided by the supplier?
• How can I check if the safety data sheet provided by the supplier is correct?
• How long is a safety data sheet valid, and how often should it be updated?
• Who can create a safety data sheet?
• Is it enough if I download the safety data sheet from the internet?
• In our company, English is mandatory, so the safety data sheets are not translated into the national language of the country, since everyone can read them. Is this in compliance with the regulations?
• How can I determine which of my distributed products are subject to PCN notification and which are not?
• What kind of data do I need for the PCN notification?
• I have already created the UFI codes for my products using the online UFI generator and these are also printed on the product labels. Does this mean that I have fulfilled my PCN notification obligations?
• At the request of our customers, we have made a PCN notification for our product which is not classified as hazardous. Does the generated UFI code need to be included on the label?
• We import mixtures classified as hazardous to health under CLP from China as raw materials, which we use in the manufacture of our own products, which are also classified as hazardous under CLP. We have already made PCN notifications to the designated authorities in the countries where our products are marketed. Do we have any further notification obligations?

 

Questions related to our services

• I would like to order the creation of a safety data sheet, but I do not know what kind of quote I should request. How can I decide among the services?
• What does the compilation of the safety data sheet mean, and what kind of documents are needed?
• What does translation with adaptation mean?
• What is a safety data sheet revision?
• What does the creation of a label draft mean, and what kind of documents are needed?
• What kind of priority services are available?

 

Questions related to the order and delivery process

• How can I request a quote?
• When requesting a quote, what kind of information do I need to provide in the e-mail?
• Is there any discount for ordering several data sheets?
• In what format should I send the source document?
• What will the finished safety data sheet look like?
• Is it possible to include my own company logo in the safety data sheet?
• How long is the ToxInfo quotation valid?
• What should I do if I want to order a safety data sheet service?
• What happens after I accept the quotation?
• What information do I need to provide for the order?
• How can I know if the source documents attached to the order form are appropriate?
• Do I have to fill out a new data request form for each order?
• How many safety data sheets can I order at once?
• How long will my order take?
• Will I always receive my order on the day indicated in the confirmation?
• Is there any kind of guarantee for the completed data sheet?
• Do I have to pay in advance?
• If I paid against a pro forma invoice, will I still receive a final invoice?

 

Questions related to chemical safety

 

What is the UFI? Do I have to do anything with it as a distributor?

The unique formula identifier (UFI) is a 16-character code to be indicated on the label of hazardous mixtures.

The UFI is also an element in the harmonised notification process of hazardous mixtures to poison centres (PCN).

The PCN notification including the UFI code has to be made by those who place the product on the market in the given country.

Resellers are generally not subject to the notification obligation.

If the label of the product is damaged, or if the manufacturer changes the composition of the product in such a way that a new UFI code has to be generated, then the product label needs to be replaced or updated. In these cases, the reseller may have obligations.

You can read a summary about distributors’ other tasks here.

I would like to have a safety data sheet and label for cosmetics. What information do I need to provide? Do the requirements of chemical safety also apply to this product group?

It is not required to create a safety data sheet for cosmetic products or to make one available to customers. Cosmetic products are not subject to the provisions of chemical safety regulations.

However, a safety data sheet may be recommended and appropriate in certain cases.

On the other hand, for placing cosmetic products on the market, a label prepared in accordance with Regulation (EC) No 1223/2009 is definitely important.

What is the purpose of a safety data sheet?

Safety data sheets are important communication tools in the supply chain, helping each participant to fulfil their obligations related to the management of risks arising from the use of substances and mixtures.

You can find more information on the importance of the safety data sheet here.

Do all chemical products require a safety data sheet?

The REACH Regulation clearly defines the products for which a safety data sheet is mandatory and the cases where a safety data sheet must be made available on request.

Of course, if certain well-defined conditions are met, the safety data sheet does not have to be prepared and provided to customers.

The rules on providing a safety data sheet can be found here.

Do I always have to have a safety data sheet in the language of the target country, or can I use the safety data sheet in a foreign language (e.g. English) provided by the supplier?

Activities involving hazardous substances or mixtures in EU countries require a safety data sheet in the language of the target country, unless the Member State decides otherwise.

In the case of products which do not require the compilation and provision of safety data sheets, but the supplier provides them in English (or another foreign language), they can be used as an information source for taking safety measures.

If you buy chemical products for your own industrial use (also as a downstream user), you have to have the safety data sheet in the target language, but it is not necessary to change the language of the label (the product is not placed on the market and the information provided to workers is based on the SDS).

How can I check if the safety data sheet provided by the supplier is correct?

As a reselling distributor, regarding safety data sheets, it is not your responsibility to check the content of the documents received. However, you should at least check the format of the provided safety data sheet. Regarding product labelling, you should check the following:

• the content of the product label is consistent with the safety data sheet
• it has been prepared in accordance with the current CLP Regulation

 

If you are a distributor obliged to notify (your company is the first distributor in the target country), then you are also responsible for the content of the safety data sheet. In this case, it is your task to prepare the safety data sheet in the target language and make the notification as well.

As an importer, you have similar responsibilities regarding the safety data sheet and labelling as above (there are other additional tasks).

As a downstream user, you also have to check the documents because the information they contain is necessary for creating safe working conditions. As a downstream user formulating mixtures, you have to create your own products’ SDSs based on the safety data sheets of the raw materials.

When purchasing a product, try to choose a reliable supplier who can guarantee that the information in the original safety data sheet is accurate and compliant with the regulations.

How long is a safety data sheet valid, and how often should it be updated?

Safety data sheets do not have a “validity” or “expiry” date.

The validity period of safety data sheets is not determined by the date of issue or revision. The validity (adequacy) of a safety data sheet depends on its compliance with the applicable regulations and legislation.

The revision and update of safety data sheets may be necessary when there is new, essential information about the product or changes in the content/format requirements laid down in regulations.

Who can create a safety data sheet?

For the creation or “translation” of a safety data sheet, having a special qualification is not explicitly required by law.

Any “competent person” can create a safety data sheet if he/she also accepts responsibility for the non-negligible consequences regarding its compliance.

The safety data sheet is the number one “information carrier” of chemical products in the supply chain. Read more about the functional importance of the safety data sheet here.

We would like to emphasise that the label, which contains information for users about hazards, appropriate use, and basic disposal instructions, can only be prepared based on a correct safety data sheet.

Safety data sheet translation is also the result of a complex, professional process, and it is not always done properly, even when using specialised safety data sheet authoring software created by “experts”.

Click here for a sample data sheet prepared in accordance with the current formal and content requirements.

Is it enough if I download the safety data sheet from the internet?

Recently, it has become a “common” practice that companies “publish” safety data sheets on their websites, making them available for everyone. However, this practice is not appropriate for several reasons.

A company can only fully comply with the obligation to transfer a safety data sheet as set out in the relevant legislation if it “actively” transfers the data sheet and can provide some form of proof of this later.

The fact that you can download it from a website does not constitute “handing over” the safety data sheet.

In our company English language is a must, thus the safety data sheets are not translated to the national language of the country, since everyone can read them. Is this in compliance with the regulations?

The safety data sheet must be provided in the language of the target country. Even if colleagues can read it in English, in the event of an accident or another hazardous situation, it is not certain that the person involved in the response will be able to speak the language.

This possibility was taken into account by legislators when they laid down clear rules on the language in which the safety data sheet should be made available to the user of the substance/mixture.

Even for your own industrial use, it is necessary to prepare a safety data sheet in the target language and make it available to workers at the workplace (a “hidden” data sheet in the office is not appropriate). In the case of industrial use, however, it is not necessary to relabel the product in the target language if the original language is clearly indicated on the packaging.

How can I determine which of my distributed products are subject to PCN notification and which are not?

• First of all, you should define your role in the supply chain. The distributor and importer responsible for the first placing on the market have a “default” notification obligation. As a reselling distributor, the company only has a PCN notification obligation if the supplier who is obliged to notify has not done so. It also follows that, as a reseller, you need to make sure that the product has a PCN notification in the Member State where it is sold.
• If the product is classified based on health or physical hazards in accordance with CLP (in other words, it is hazardous), the mixture has to be notified.
• Determine when your notification obligations may arise.
• Distinguish products based on their use: consumer, professional, or industrial. From 1 January 2021, mixtures intended for consumer and professional use have to be notified. From 1 January 2024: products for industrial use. From 1 January 2025: end of the grace period for mixtures already on the market.
• Examine certain special product categories exempt from notification and/or outside the scope of CLP.

Read further information on the notification obligation here.

What kind of data do I need for the PCN notification?

You need the following information for the notification:

• Name and contact details of the contact person (who will be able to respond to any enquiries from the authorities at short notice)
• Trade name of the product
• UFI code
• Type of use (industrial, professional, or consumer)
• Type of submission (for the first product notification, choose Initial submission)
• Product type, in accordance with the EuPCS category
• Country of the notification (where the product is placed on the market and used)
• Language of the notification
• Product packaging (packaging material, package size)
• The exact composition of the hazardous mixture and the concentration of the ingredients in the mixture (preferably the ingredients should add up to 100%). It is usually not enough to give only the ingredients indicated in the safety data sheet.
• CLP classification of all ingredients
• CLP classification of the mixture + relevant hazard statements
• Label elements of the mixture
• Safety data sheet of the mixture (mandatory to upload only in certain cases)
• Toxicological data for the mixture (based on Section 11 of the SDS)
• pH value of the mixture (if not relevant, provide the reason why)
• Colour and physical state of the mixture (based on Section 9 of the SDS)

I have already created the UFI codes for my products using the online UFI generator and these are also printed on the product labels. Does this mean that I have fulfilled my PCN notification obligations?

The existence of the UFI code alone is not sufficient; “blank” UFI codes without a PCN notification should not be included on the label. Therefore, after the UFI code has been generated, the PCN notification must be made, and only then should the UFI code be applied to the label.

At the request of our customers, we have made a PCN notification for our product which is not classified as hazardous. Does the generated UFI code need to be included on the label?

If you choose to make a voluntary PCN notification for your non-hazardous product, it is not mandatory (only optional) to indicate the UFI code on the label.

We import mixtures classified as hazardous to health under CLP from China as raw materials, which we use in the manufacture of our own products, which are also classified as hazardous under CLP. We have already made PCN notifications to the designated authorities in the countries where our products are marketed. Do we have any further notification obligations?

Yes, you have additional notification obligations. As an importer, you also have to make a PCN notification for the imported hazardous product in the country where you manufacture your own product, as importing is also considered a type of “placing on the market” under the relevant regulation.

Questions related to our services

 

I would like to order the creation of a safety data sheet, but I do not know what kind of quote I should request. How can I decide among the services?

The first step is to check what kind of document(s) you have.

If you have received a data sheet in a foreign language, then you need a translation with adaptation.

If you have a data sheet in the target language but you are not sure whether it complies with the relevant regulations, then you can order a revision of the safety data sheet.

If you have a new chemical product, or if you have not received a safety data sheet from the supplier, you need to order the compilation of a safety data sheet. In this case, you have to provide the data and information set out in the service description.

Of course, our Customer Service will also help you find the right service.

What does the compilation of the safety data sheet mean, what kind of documents are needed?

The compilation of a safety data sheet is a complex, multi-step process in which we prepare a safety data sheet based on the available data and in accordance with the relevant requirements. This service is mainly used by manufacturers (or downstream users who formulate mixtures) and distributors responsible for placing the product on the market for the first time, if the safety data sheet is not available in the target language.

For the compilation, we need the trade name of the product, a precise description of its composition, and other known information about the product and its ingredients. The full list of required documents will be specified at the time of ordering.

What does the translation with adaptation mean?

If the supplier can only provide a safety data sheet in a foreign language, then it needs to be translated. When translating the safety data sheet, it is important to avoid literal translation, because otherwise much information would be transferred into the target-language data sheet that is only relevant in the country of the original document and, of course, will not comply with the legislation of the target country. Furthermore, the content and format of the safety data sheet are such that some parts of the wording are legally binding and must be used in the form prescribed by the regulation (e.g. section headings, hazard and precautionary statements, etc.).

Translation with adaptation means that the data sheet is not just translated, but we also make sure that the appropriate terminology is used and that the relevant parts are adapted (localised) in accordance with the legislation in force in the target country and the EU.

What is a safety data sheet revision?

A safety data sheet may need to be revised in many cases.

The most important case is when there are changes in the content/format requirements laid down in regulations.

Another common reason is when a new safety data sheet becomes available in a foreign language, and there are changes that require the translated version of the sheet to be updated.

Furthermore, there may be significant changes in the composition of the product, or new information may become available regarding product hazards, which affect the classification and the related risk management measures.

As a result of the safety data sheet revision service, we provide an SDS to our clients that is in compliance with all relevant legislation in force at the time of preparation.

What does the creation of label draft mean, what kind of documents are needed?

If you distribute a hazardous substance or mixture, it is necessary that the product is labelled in accordance with the legislation in force. Based on the safety data sheet provided, we will determine the mandatory label elements required for the product from a chemical safety point of view and provide them in an editable Word format.

What kind of priority services are available?

If you need a safety data sheet urgently for any reason, we have two types of priority service to choose from.

In the case of Rapid service, we can prepare the requested safety data sheets within 3 working days. This service is available when ordering a maximum of 3 data sheets.

In the case of Express service (1 working day), we will prepare the requested safety data sheet no later than the end of the next working day. This service is available when ordering a maximum of 1 data sheet.

When requesting a priority service, please always take weekends and public holidays into account, as they may delay the delivery date. For more information on applicable prices, please refer to the order form.

In the case of full capacity, we may not be able to provide Rapid or Express service. If that is the case, we will let you know before sending the confirmation.

Please contact our Customer Service by phone for quicker administration.

Questions related to the order and delivery process

 

How can I request a quote?

We suggest requesting a quote for safety data sheet creation by filling out the online form on our website.

To request a quote directly by e-mail, please use the e-mail address found under the Customer Service menu. Quote requests will be processed and answered within 24 hours. In cases of extreme urgency (when ordering Rapid or Express service), we recommend contacting our Customer Service by telephone.

When requesting a quote, what kind of information do I need to provide in the e-mail?

Please describe exactly what kind of service you need and for how many products you would like to use the service. If you need a translation or a revision of an outdated data sheet, and the documentation to be translated/revised is already available, please attach the document(s) to the quote request to speed up the process.

Is there any discount for ordering several data sheets?

We offer a significant quantity-based discount for ordering several data sheets at once. The discount rate will be explained in the quote.

The quantity discount is only valid for translations ordered for the same target language.

In what format should I send the source document?

For our workflow, we prefer Word files or non-secured PDF files.

How will the finished safety data sheet look like?

We deliver our safety data sheets to customers with a uniform layout.

If your company policy requires different imagery/colours, we can prepare and deliver the safety data sheet according to your request after prior consultation.

Is it possible to include my own company logo in the safety data sheet?

Of course, you can request the safety data sheet with your own company logo, but please do not forget to fill out the relevant parts of the order form and send the logo together with the order in JPEG format and appropriate resolution.

How long is the ToxInfo quotation valid?

Every quote issued by ToxInfo also contains its validity date.

After the validity date, our company sends an updated quote with a new reference number, typically with the same price but with a different delivery date.

What should I do if I want to order a safety data sheet service?

If you accept our quotation, please confirm your order by contacting our customer service via e-mail or phone. Our quotation will be considered accepted and will constitute a one-time assignment between the parties, even if your company places the order using its internal purchase order system while referring to the reference number of our quotation.

What happens after I accept the quotation?

Within 1–2 business days after accepting our quotation, you will receive an order confirmation via e-mail. This confirmation will include the name of the service(s) ordered, the completion deadline, and the service fee, in line with the quotation.

What information do I need to provide for the order?

In addition to the documents specified by our customer service, most of our services require certain data and information mandated by chemical safety regulations to ensure compliance. We will send you a service-specific data request form along with our order confirmation.

If you need assistance in filling out the data request form, our customer service team is available at +36 70 637 6986.

We also accept purchase order forms standardised by your company. However, in such cases, please make sure to include all the required information found in our data request form, as it is essential for preparing the SDS.

How can I know if the source documents attached to the order form are appropriate?

After confirming your order, we will thoroughly review the submitted documentation. If any essential documents are missing or incomplete, your assigned corporate contact person will notify you immediately about the specific information or corrections needed.

In rare cases, deficiencies in the documentation may only become apparent later during the expert review or preparation phase. Depending on the issue’s complexity, either your contact person or one of our experts will reach out to clarify any concerns. In such cases, the completion deadline may be extended beyond the original timeframe stated in the order confirmation.

Do I have to complete a new data request form for each order?

Yes, a data request form completed for a previous order cannot be reused for a new order. The form contains specific questions relevant to the particular product(s) (e.g. trade name, intended use, etc.).

How many safety data sheets can I order at once?

There is no upper limit to the quantity that can be ordered at once. Our prices are quantity-based; we can give you a discount based on the number of data sheets.

For larger quantities, you can order at a better price, or we recommend joining the MSDS-Europe Customer Support Program.

How long will my order take?

Our normal delivery time is 8–10 working days from the date of order, but you can also choose Rapid or Express service in the order form.

The document sent with the confirmation contains the delivery date.

We deliver the order on the day indicated in the confirmation, by the end of the working day at the latest.

Will I always receive my order on the day indicated in the confirmation?

No. We deliver the order after receiving payment of the pro forma invoice. You will be notified on the day when the order is completed and, where applicable, asked to check that the transfer has been made.

Our contractual clients have the option of payment against a final invoice. Please contact our customer service for information on our contract arrangements.

Please refer to the order reference number for easier identification when making the transfer.

Is there any kind of guarantee for the completed data sheet?

Our company offers a full professional and financial guarantee for the safety data sheets we prepare. Our financial guarantee covers all direct and indirect damages. Our customer service will respond to any comments within 24 hours.

Do I have to pay in advance?

Yes, but not in every case.

Our company policy prefers payment against a pro forma invoice. The payment deadline of the pro forma invoice sent with the confirmation is the delivery date of the order.

Our contractual clients can pay against a final invoice.

If I paid against a pro forma invoice, will I still receive a final invoice?

In all cases, we will send you a copy of the final invoice electronically for VAT purposes after payment against the pro forma invoice and after the service has been provided.

If you wish to receive the invoice by post, please let us know explicitly.

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