Safety data sheet requirements under EU REACH, OSHA and UK REACH

Safety data sheet requirements in the EU, US and Great Britain

A safety data sheet is required, in the EU and Great Britain, for a substance or mixture classified as hazardous, a PBT or vPvB substance, or a Candidate List substance (REACH Article 31 and UK REACH Article 31). In the US it is required for every hazardous chemical under OSHA's Hazard Communication Standard, 29 CFR 1910.1200. Safety data sheet requirements in all three places use 16 sections in the same order. Exemptions and update deadlines differ.

When an SDS is required in the EU

Under REACH Article 31(1), the supplier must give the recipient an SDS when:

• the substance or mixture meets the Classification, Labelling and Packaging (CLP) criteria for classification as hazardous;
• the substance is persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB), under Annex XIII;
• the substance is on the Candidate List for any other reason.

A mixture that is not classified as hazardous can still need one. Under Article 31(3), the supplier must provide an SDS on request if the mixture contains:

• a substance with a health or environmental hazard at 1% or more by weight for non-gaseous mixtures, or 0.2% or more by volume for gaseous mixtures;
• in a non-gaseous mixture at 0.1% or more by weight, a substance in any of these categories: carcinogenic Cat 2; toxic to reproduction Cat 1A, 1B or 2; skin or respiratory sensitiser Cat 1; effects on or via lactation; PBT/vPvB; or Candidate List;
• a substance with an EU workplace exposure limit.

Hazardous products sold to the general public in the EU do not need an SDS if the product comes with enough safety information. A downstream user or distributor can still request one (Art 31(4)).

Where no SDS is required, Article 32 still requires suppliers to pass on relevant substance information. This includes available registration numbers, authorisation status, restriction details and information needed for risk management. Supply it free of charge, at the latest at first delivery. The same update triggers and 12-month resend rule apply.

The 16 sections of an SDS

How many sections does an SDS have? It has 16, in a fixed order, under both REACH Annex II Part B and OSHA (g)(2):

The OSHA wording is a little shorter ("Identification", "Hazard(s) identification"). Its Section 16 includes the date of preparation or last revision.

What SDS sections 1, 2, 4 and 9 contain

Under EU Annex II, Section 1 identifies the product and supplier and gives an emergency phone number. In the EU, subsection 1.1 holds the UFI (unique formula identifier) where a mixture has one and it is shown on the SDS. Subsection 1.4 gives the emergency number. Where an official advisory body exists, its number must be given and can be enough on its own. Limits on availability, such as office hours, must be stated. The 2024 OSHA rule adds a US address and US phone number to Section 1, from the compliance dates below.

Section 2 covers hazards identification. In the EU, subsection 2.3 must say whether the substance is PBT/vPvB and whether it has endocrine disrupting properties under the Candidate List, or under the criteria in Delegated Regulation (EU) 2017/2100 or Regulation (EU) 2018/605. For mixtures, that applies to each such substance at 0.1% or more.

Section 4 sets out first aid measures, the fourth of the 16 headings in both the EU and US formats.

Section 9 lists physical and chemical properties. In the EU, if a property is missing or does not apply, give the reason. The same 2024 rule adds particle characteristics at the end of the US Section 9 list, on those dates.

EU SDS format under Regulation (EU) 2020/878

Regulation (EU) 2020/878 replaced REACH Annex II. It has applied since 1 January 2021. Old-format sheets were allowed until 31 December 2022, so this format has been mandatory since 1 January 2023. Annex II has not changed since then (consolidated text, June 2026). The format rules in Annex II require the following:

• A competent person prepares the SDS, and the supplier makes sure that person gets training, including refresher training.
• The text must be "simple, clear and precise, avoiding jargon, acronyms and abbreviations". Phrases like "may be dangerous", "no health effects", "safe under most conditions of use" or "harmless" are banned.
• Page 1 carries the compilation date. A revised SDS shows "Revision: (date)" and the version it replaces. Section 16 flags the changes unless they are marked elsewhere.
• Every page, annexes included, is numbered. Each page shows the length ("page 1 of 3") or whether a page follows ("Continued on next page" or "End of safety data sheet").
• No subsection may be left blank.
• Each relevant section states whether it covers nanoforms, and which ones.
• Section 3 gives specific concentration limits, M-factors and acute toxicity estimates, where available.
• Subsection 8.2 specifies glove material, thickness and typical or minimum breakthrough time for hand protection.

If you must prepare a chemical safety report under Article 14 or 37, attach relevant exposure scenarios to the SDS (Art 31(7)). Downstream users include relevant scenarios in their own SDS, and distributors pass those scenarios on.

ECHA's guidance on compiling safety data sheets is the current guidance. The PDF is dated 16/12/2020.

Language, delivery and updates in the EU

The SDS must be in an official language of each Member State where the product is sold, unless that country provides otherwise (Art 31(5)).

It must be dated (Art 31(6)). Supply it free of charge, on paper or electronically, no later than the date of first supply (Art 31(8)).

Under Art 31(9), update it "without delay" when new information may affect risk management, when new hazard information appears, when an authorisation is granted or refused, or when a restriction is imposed. Mark it "Revision: (date)" and send the new version free of charge to every recipient supplied in the previous 12 months. After registration, updates must carry the registration number.

No adopted Annex II amendment covers digital SDSs. Parliament lists the wider REACH revision as "Blocked" (updated 20 September 2026). Regulation (EU) 2024/2865 amends CLP, not REACH Article 31 or Annex II.

US requirements under OSHA HazCom

Under 29 CFR 1910.1200(g), chemical manufacturers and importers must obtain or develop an SDS for each hazardous chemical they produce or import. They send it with the first shipment, and again with the first shipment after an update. Distributors pass it on the same way. Employers must keep one for each hazardous chemical they use, readily accessible to employees in their work areas during each shift. Electronic access is fine if nothing blocks immediate access.

The SDS must be in English. Employers may keep copies in other languages too. New significant hazard or protection information must be added within three months.

OSHA says sections 12 to 15 must be included for GHS consistency, but it "will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction." Appendix D calls them "not mandatory" and lets information within a section appear in any order. Where no information exists for a subheading, the SDS must clearly say so.

The 2024 update and the moved deadlines

OSHA's 2024 final rule took effect on July 19, 2024 and aligns HazCom mainly with GHS Rev. 7. Besides the Section 1 and Section 9 changes above, it sets prescribed concentration ranges in Section 3 when a figure is withheld as a trade secret.

A rule of January 15, 2026 pushed the compliance dates back four months:

During the applicable transition period, firms may follow the 2012 standard, the 2024 standard, or both. The substance-supplier deadline has already passed as of October 2026.

MSDS vs SDS

An MSDS (material safety data sheet) is the old name. OSHA's 2012 rule aligned HazCom with GHS and set a fixed format. OSHA describes SDSs as "formerly MSDSs", with content "largely the same as the MSDS" in a 16-section layout.

Great Britain under UK REACH

UK REACH Article 31 keeps the EU triggers and on-request cases, with GB workplace exposure limits. The SDS "shall be supplied in English and may also be supplied in any other language". Dating, the 16 headings, free supply by first delivery and the 12-month update rule all match the EU. HSE says SDSs "are required by the UK REACH Regulation".

The GB Annex II text is the version from Regulation (EU) 2015/830 and does not include the 2020/878 additions, such as the UFI and nanoform text. S.I. 2026/484, in force since 21 May 2026, deleted Annex II points 3.2.1(a)(iv) and (vi), which referred to the GB notification database.

Reusing an SDS across markets

Don't assume one market's SDS meets another market's rules. For the EU, check the Annex II numbered subsections, sections 12 to 15, page markings, revision details and required language. For the US, check OSHA's requirements, including classification, US supplier contact details and exposure limits. A GB-compliant sheet also needs a check against the EU's 2020/878 additions before EU supply.

Update timing differs too. EU Article 31(9) and UK Article 31(9) require an update without delay, and a free resend to recipients supplied in the previous 12 months. OSHA gives three months to add significant new hazard or protection information.

To check the SDS rules for a specific substance, you can ask RegAffairs AI, which answers from the official texts with citations.