Why didn’t my partner accept our safety data sheet? – Error log and compliance checklist
MSDS-Europe – Why did my partner refuse my Safety Data Sheet?
The safety data sheet is a fundamental document of chemical safety, so our business partners are right to expect that the SDS they receive complies with all legal requirements. If a partner has rejected our safety data sheet, a compliance deficiency is usually the reason. Below, we present the most common reasons and a practical checklist to help avoid SDS rejections.
Common reasons why an SDS is not accepted
Safety data sheet in an inappropriate language
One of the most frequent reasons is that the safety data sheet is not prepared in the language required by the recipient or the authorities. The REACH Regulation stipulates that the SDS must be provided in the official language of the Member State where the product is placed on the market. In Hungary, for example, a Hungarian-language safety data sheet is mandatory, and the partner is not obliged to accept a document in a foreign language.
Incomplete or outdated SDS format
It may happen that the SDS is linguistically correct, but formally or content-wise incomplete. Previously, this was often called a check for “830 compliance”, referring to Regulation (EU) 2015/830, which defined the 16-section structure and detailed content requirements.
However, a few years ago a new EU requirement entered into force: Regulation (EU) 2020/878 replaced the previous rules. From 1 January 2023, only SDSs in the format required by Regulation (EU) 2020/878 are acceptable in the EU; therefore, all older sheets had to be updated by the end of 2022.
“878 compliance” means that the SDS also contains the new information required by the regulation – for example, data on nanoforms, endocrine-disrupting properties, ATEs and M-factors. An SDS prepared using an outdated template will most likely be rejected.
The customer’s right to an appropriate SDS
Our partner – as the recipient of a hazardous substance or mixture – is entitled to receive, and is often obliged to obtain, a proper, up-to-date safety data sheet. This is also supported by Hungarian legislation: Decree 25/2000. (IX. 30.) EüM–SZCSM stipulates that Hungarian companies must obtain a safety data sheet from the supplier that complies with the applicable regulation. Without it, the customer cannot fulfil their own chemical safety obligations, so they may rightly reject an incomplete or outdated SDS and insist on an up-to-date version.
Practical checklist
The following checklist helps suppliers and distributors review whether their safety data sheet meets the requirements before handing it over to a partner:
- Correct language: Make sure the SDS is prepared in the official language of the country where the product is placed on the market.
- Correct classification and labelling: Check that the hazard classification shown in the SDS complies with the CLP Regulation. All required H- and P-statements and hazard pictograms must be included.
- Up-to-date version: The SDS must show the issue date and version number, and the document itself must comply with the current format under Regulation (EU) 2020/878. If the last update was before 2023, prepare a new version so that the newly required elements (e.g. endocrine-disrupting properties) are included.
- Attachments: Check that all necessary annexes are attached.
Correcting typical errors
If the review shows that the safety data sheet does not meet expectations, it must be corrected as soon as possible. If the problem is linguistic, in most cases we ourselves must ensure that an appropriate local-language SDS is prepared. It is advisable to involve a qualified translator and have the translation proofread by a chemical safety expert, because compliance requires not only linguistic accuracy but also professional accuracy.
If the SDS format or content is outdated, it must be updated according to the current regulations. This means incorporating the newly required elements and, if necessary, modifying the classification.
However, this is not an easy task, since ensuring SDS compliance is a complex, continuously changing field, and most companies do not have in-house expertise to manage it.
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