When an SDS is required, how it must be supplied and revised, and what belongs in the 16-section UK REACH Annex II structure.
A UK chemical supplier must provide a compliant Safety Data Sheet when UK REACH requires one, in English, free of charge and no later than first supply. The sheet must describe the product actually supplied, use the prescribed sixteen-section structure and be revised and redistributed when specified new information or regulatory decisions arise.[1]
Article 31 requires the supplier to provide an SDS for a substance or mixture classified as hazardous under GB CLP. It also covers a substance that is persistent, bioaccumulative and toxic, very persistent and very bioaccumulative, or included on the candidate list for other specified reasons. HSE summarises the practical position: an SDS is a must where a hazardous chemical is supplied for workplace use, whether packaged or not.[2]
An unclassified mixture can still require an SDS on request. The statutory triggers include at least one health- or environmental-hazardous substance at one per cent by weight in a non-gaseous mixture or 0.2 per cent by volume in a gaseous mixture; certain substances of higher concern at 0.1 per cent by weight in a non-gaseous mixture; or a substance with a GB workplace exposure limit.[1]
Where a hazardous product is offered or sold to the general public with enough information for safe use and environmental protection, an SDS need not automatically accompany it unless a downstream user or distributor requests one. That exception should not be used to withhold sheets from trade recipients. Capture whether the customer acts as an employer, professional user, formulator or distributor.[1]
The obligation sits with the supplier to the recipient. Importers, formulators, repackers and own-brand suppliers therefore need a sheet aligned to their supply, not merely an untranslated document filed from an overseas source. A distributor must pass relevant supply-chain information onwards; HSE states that a business supplying chemicals to others must pass on information through SDSs.[3]
The SDS must be in English and may additionally be supplied in another language. It must be free of charge, on paper or electronically, no later than the date of first supply. Build delivery evidence into order processing: an accessible attachment or controlled electronic delivery is stronger evidence than assuming the recipient can search a website.[1]
Match product identifier, supplier identity, emergency contact, composition, classification and transport description across SDS, label, specification and shipping documents. For imported or repacked products, verify units and UK terminology. A change of brand or supplier can make a technically accurate source sheet unsuitable for the transaction.[1]
The SDS must be dated and carry these headings in order: 1 identification; 2 hazards identification; 3 composition or information on ingredients; 4 first-aid measures; 5 firefighting measures; 6 accidental release measures; 7 handling and storage; 8 exposure controls and personal protection; 9 physical and chemical properties; 10 stability and reactivity; 11 toxicological information; 12 ecological information; 13 disposal considerations; 14 transport information; 15 regulatory information; and 16 other information.[1]
UK REACH Annex II governs the detail beneath those headings. Preserve the headings even where particular information is unavailable or not applicable, and explain the position rather than silently deleting a section. Ensure Section 2 matches the label classification, Section 3 supports the disclosed hazardous ingredients, and Sections 7 and 10 clearly communicate incompatible storage and reaction risks.[4]
Section 8 should connect exposure limits and controls, while Section 14 must be reconciled with the transport classification used for consignment. Do not copy values between similar grades without technical substantiation. Concentration, stabiliser, available active content or physical form can change classification and handling advice.[4]
An SDS provides hazard, handling, storage and emergency information that helps an employer assess risk. HSE is explicit that the sheet itself is not the workplace risk assessment. The employer must consider the task, quantity, exposure route, frequency, people, controls and site conditions under COSHH.[3]
Supplier wording should therefore be specific enough to support assessment without pretending to know every workplace. Avoid generic personal-protective-equipment text unsupported by the hazard and exposure scenario. Recipients should use the SDS alongside their process assessment and operating controls; the companion article on COSHH and warehouse chemical storage addresses that distinction.[3]
The supplier must update the SDS without delay when new information may affect risk-management measures or new hazard information becomes available, when an authorisation is granted or refused, or when a restriction is imposed. The new dated version must be identified as “Revision” with its date.[1]
The revised sheet must be sent free of charge, on paper or electronically, to former recipients supplied within the preceding twelve months. Updates following registration must include the registration number. Annex II also requires changes in a revised sheet to be brought to recipients' attention in Section 16 unless identified elsewhere.[4]
Not every editorial correction necessarily invokes those statutory redistribution events, but all changes need controlled review. Maintain revision history, approval, effective date and a recipient list. Link raw-material or regulatory alerts to the affected finished products so that revised information reaches labels, transport systems, warehouse instructions and customers consistently.[1]
Before release, compare the SDS with the exact formulation and current GB classification. Check English language, date, sixteen headings, supplier details, emergency number, uses, physical data, controls, incompatibilities, disposal, transport and revision information. Confirm any exposure scenario annex is attached where required by a chemical safety report.[1]
Keep the approved master separate from uncontrolled customer copies. Provide a clear route for technical queries and treat customer evidence of changed properties or hazards as an input to competent review, not merely a complaint. Defra has policy lead responsibility for UK REACH SDS requirements, while HSE provides the UK REACH and CLP helpdesk and enforcement guidance.[2]
Reviewed on . Next review due .