Safety data sheet: the supplier document to check, version and keep up to date

In brief

• A safety data sheet (SDS) is not an administrative document to be filed away: it is the document that determines your chemical risk assessment, your workstation instructions and your evidence during inspections.
• Its content is governed byAnnex II of Regulation (EC) No 1907/2006 (REACH): 16 sections, in a defined order, since the version introduced by Regulation (EU) 2020/878.
• An SDS must be provided free of charge, at the latest on first delivery, in the recipient's language (Article 31). An SDS received in English at a French site is a documentary gap.
• Five checks are enough to rule out most unusable SDSs: version, revision date, language, CAS/EC identifiers, consistency with the SVHC declaration.
• An SDS has no expiry date, but it does become outdated: any change in composition, classification, restriction or limit value requires the supplier to update it.
• The real industrial issue is one of collection and flow: obtaining the right version, for the right reference, at the right time, and being able to prove it.

1. Safety data sheet: definition and regulatory framework

A safety data sheet (SDS) is a regulated document, required by Annex II of the REACH Regulation, which describes the hazards of a substance or mixture, the conditions for safe use, the risk management measures and the regulatory obligations associated with placing it on the market.

Three elements of the framework must be established before looking at the content.

The obligation to provide. Article 31 of the REACH Regulation requires the supplier of a hazardous substance or mixture to provide an SDS compliant with Annex II. It must be provided free of charge, on paper or electronically, at the latest on first delivery, and the document must be written in the official language(s) of the Member State where the product is placed on the market. In France, Article R. 4411-73 of the Labour Code reinforces this requirement on the user side: the employer must hold the SDSs of the hazardous chemical agents used and make them available to workers, their representatives and the occupational physician.

The format. Annex II was rewritten by Regulation (EU) 2020/878, applicable since 1 January 2021, with a transitional period ending on 31 December 2022. This version introduced theunique formula identifier (UFI), derived from Annex VIII of the CLP Regulation, as well as specific requirements for nanoforms: the SDS must indicate, in the relevant sections, whether it covers one or more nanoforms and which ones.

The supplier logic. An SDS is never an isolated document: it is linked to a product, a supplier, a version and uses. It is this chain of links that must be organised, because that is what is missing in audits, not the regulation. It is part of the allocation of responsibilities in the supply chain set by REACH, from the manufacturer to the downstream user.

2. The 16 sections of Annex II: what each one allows you to check

The table below serves as a quick reading grid. It does not replace the text of Annex II, but it indicates, for each section, the checkpoint that is useful to a Quality, HSE or Purchasing team.

The three sections most closely scrutinised in a document review

Section 3 determines everything else. Without CAS and EC identifiers, it is impossible to cross-check the SDS with your list of monitored substances, with the SVHC Candidate List or with an Annex XVII restriction. An SDS that mentions substances "without a number" is an unusable SDS, even if the document appears complete.

Section 8 determines occupational health. Occupational exposure limit values, DNELs and PNECs feed into your chemical risk assessment and medical surveillance. An empty section 8 shifts the burden of proof onto your site.

Section 15 determines compliance. This is where the status with regard to Annexes XIV and XVII can be read and, where applicable, the presence of a Candidate List substance above 0.1% w/w in a mixture. A separate SVHC declaration may exist, but it must be consistent with this section.

3. SDS, eSDS and exposure scenarios: when one replaces the other

The confusion between "SDS" and "eSDS" (or extended SDS) creates two symmetrical errors: expecting exposure scenarios everywhere, or never requesting them.

An eSDS is not a different document: it is the same SDS, with exposure scenarios annexed. Each scenario describes the conditions under which a substance can be used safely: process, quantity, duration, temperature, ventilation, personal protection, waste management. Our guide details when the SDS is extended with exposure scenarios and how to check their coverage.

The obligation to annex scenarios depends on thechemical safety assessment (CSA), itself triggered by the regulatory status of the substance - in particular substances subject to authorisation - and, for registered substances, by exceeding the 10 tonnes per year threshold combined with the hazard criteria (classification, PBT/vPvB). Practical consequence: the 10 t/year threshold alone is not enough to guarantee the presence of scenarios, and a substance subject to authorisation does not necessarily include them.

The check that is most often missing

At a user site, the question is not "do we have the eSDS?" but " is our actual use covered by a scenario? ". A degreasing workstation operating at 60°C with ventilation different from that in the scenario is not covered, even if the SDS is in the binder. If the use is not covered, the downstream user must inform its supplier in writing so that it can extend its assessment, or carry out its own chemical safety assessment. This check must be dated, per use and per SDS: it is the document requested during inspections.

4. The 5 admissibility checks for a supplier SDS

These five checks are deliberately few in number: they must be possible to carry out in a few minutes on each receipt, including by a trained buyer or storekeeper. They do not replace in-depth analysis by the HSE department.

1. The version. Every SDS must bear a version number or a revision identifier, distinct from the date. Without a version, you cannot demonstrate that you hold the latest edition, nor link a decision to a documentary state. An unversioned document is an untraceable document.

2. The revision date. It appears in section 16 and often in the footer. An old SDS is not automatically obsolete, but a gap of several years should be questioned, especially if the CLP classification, Annexes XIV/XVII or the Annex II format have changed since. The revision date also serves as the starting point for your internal review.

3. The language. In France, the SDS must be provided in French. An English version may be accepted temporarily as a working document, but it does not meet the requirement to provide it in the recipient's language and cannot be relied upon before an inspector. Set a written rule: accepted language, tolerance period, follow-up.

4. The CAS and EC numbers. In section 3, each hazardous substance must be unambiguously identifiable. The CAS number remains the most robust matching key; the EC number completes the identification for registered substances. Without these identifiers, cross-checking with the Candidate List or a restriction becomes manual, and therefore fragile.

5. Consistency with the SVHC declaration. If your supplier has sent you a declaration stating "no substance of very high concern" and section 3 or 15 mentions a Candidate List substance, there is an inconsistency to be resolved before validation. Conversely, an SDS that reports an SVHC above 0.1% w/w must trigger a check of your own information obligations. The method to cross-check section 3 with the Candidate List and assess the 0.1% threshold is detailed in our SVHC guide.

An SDS can pass all five checks and still be unusable in substance. These checks are an admissibility filter, not a technical validation.

5. Common errors observed in SDSs received

6. Life cycle and update cadence

An SDS has no formal period of validity: it is updated when the information changes. Article 31 provides that the supplier must update the SDS without delay as soon as new information on hazards or risk management measures becomes available, when an authorisation is granted or refused, or when a restriction is imposed. The revised version, dated and identified as such, must be provided free of charge to recipients supplied during the previous twelve months.

In other words, the update cadence is driven by events, not by the calendar:

In addition, there is an internalcadence, specific to your organisation: a document review of the SDS portfolio at least once a year, plus a targeted review at each revision of the Candidate List and each change to Annexes XIV and XVII. An SDS reference database not reviewed for more than a year has missed at least two revisions of the Candidate List.

Versions must be kept, not overwritten. In the event of an accident or inspection, the question will be: "which instructions were in force on the date of the incident?". An SDS replaced without archiving makes this answer impossible.

7. Document collection and monitoring method

The difficulty is not understanding Annex II, but obtaining the right version, for the right reference, in the right language, across a heterogeneous supplier portfolio. A six-step method fits into a short procedure.

Step 1 - Inventory products and uses. Cross-check the register of chemical agents, the purchasing list and the storage locations. A reference used in the workshop without an SDS is the first gap to address.

Step 2 - Define the reference database fields. A minimal table, with mandatory fields: internal reference, description, supplier, version number, revision date, language, status (accepted, conditionally accepted, rejected), date of receipt, next review, site use. Without these fields, monitoring takes place in email inboxes. These are the basic fields of any regulatory document management.

Step 3 - Integrate the request into the purchasing process. The SDS must be requested at the time of ordering or on first delivery, not discovered during an audit. A useful contractual clause: an obligation to transmit the revised version in the event of a change in composition, classification or regulatory status, within a defined period.

Step 4 - Check on receipt. Apply the five admissibility checks, with a binary verdict: accepted or not. A "conditionally accepted" status must carry a deadline for resolution, otherwise it becomes a permanent status.

Step 5 - Decide and follow up. Three outcomes: acceptance, written request for additional information, reasoned rejection. Plan a follow-up at a fixed deadline, a technical contact in addition to the sales contact, and a documented consequence in the event of no response.

Step 6 - Distribute and archive. Republish the current version to users (workshop, stores, HSE, occupational physician), archive previous versions with their date of receipt, and schedule the next review.

What the method produces

It produces three things that the regulation requires without ever naming them: dated evidence of the request and receipt, version evidence (which edition was in force), and distribution evidence (who had access to what). During an inspection, this trio is worth more than a complete but undated binder.

Our teams can help you centralise SDSs and track review deadlines across your entire supplier portfolio.

8. 10-point checklist

1. Does each hazardous substance or mixture used have an SDS in French?
2. Does the SDS bear a version number and a revision date that can be identified?
3. Does section 1 match the reference and supplier actually purchased?
4. Is section 2 consistent with thelabelling on the container received?
5. Does section 3 provide the CAS and EC identifiers of all hazardous substances?
6. Are the actual uses of the site listed in section 1.2, and do the exposure scenarios cover the working conditions?
7. Does section 8 contain limit values, DNEL/PNEC and PPE compatible with your equipment?
8. Does section 15 make it possible to reach a conclusion on Annexes XIV and XVII and the Candidate List, consistent with the SVHC declaration received?
9. Are an annual document review and written triggers (composition, classification, restriction, OEL) scheduled?
10. Are previous versions archived with their date of receipt, and do users have the current version?

Further reading: the REACH topic cluster

This page explores one point of the pillar guide on supplier REACH compliance. For substances present in the articles you place on the market, see also what falls under SCIP notification, which must be distinguished from the SDS and Article 33.

Operationally, the remaining difficulty is mechanical: maintaining, for hundreds of references and suppliers, versions, revision dates, languages, identifiers and deadlines. This is the role of a platform such as Tracklab, which centralises supplier and product data and automates document collection: each SDS is linked to the product concerned, the critical information it contains is extracted, and renewal deadlines are tracked. Regulatory interpretation, technical validation and compliance decisions remain the responsibility of the Quality, HSE, Regulatory and Purchasing teams.

Official sources

• Regulation (EC) No 1907/2006 (REACH), consolidated text - EUR-Lex
• Regulation (EU) 2020/878 amending Annex II of REACH - EUR-Lex
• SDS - update of Annex II - French national REACH regulatory helpdesk (INERIS)
• Extended safety data sheets - ECHA
• The safety data sheet - INRS (ED 6483)
• Safety data sheets: suppliers are obliged to provide them - DREETS Grand Est
• Article R. 4411-73 of the French Labour Code - Légifrance
• The REACH Regulation - French Ministry for the Ecological Transition
• All about exposure scenarios - French Ministry for the Ecological Transition