Q.01

What are the requirements for a safety data sheet?

A safety data sheet (SDS) follows the same 16-section GHS structure in the EU, the US and Canada. What differs between them is who must supply one, the language, the deadlines for updates, and how much detail each section needs. You didn't name a market, so the EU is set out in full (REACH Article 31 and Annex II, in force consolidated text of 11 May 2026), with the US and Canada after it.

EU: REACH Article 31 and Annex II

When an SDS is mandatory

  • The supplier must provide one, compiled per Annex II, if any of these apply [1]:
    • the substance or mixture meets the hazard classification criteria of CLP (Regulation (EC) No 1272/2008);
    • the substance is PBT or vPvB under Annex XIII;
    • the substance is on the Candidate List for other reasons.
  • An unclassified mixture still needs an SDS on request if it contains any of these [1]:
    • a health or environmental hazard substance at ≥1 % by weight (non-gaseous) or ≥0.2 % by volume (gaseous);
    • at ≥0.1 % by weight: a Carc. 2, Repr. 1A/1B/2, skin or respiratory sensitiser Cat. 1 or lactation substance, a PBT/vPvB, or a Candidate List substance;
    • a substance with an EU workplace exposure limit.
  • Consumer exemption: products sold to the general public with enough safety information don't need an SDS, unless a downstream user or distributor asks for one (Art. 31(4)).

Form and delivery

  • Language: an official language of each Member State where the product is placed on the market, unless that state provides otherwise (Art. 31(5)) [1].

  • Structure: the SDS must be dated and use 16 mandatory headings, from "1. identification of the substance/mixture and of the company/undertaking" to "16. other information" (Art. 31(6)) [1].

  • Exposure scenarios: anyone who must prepare a chemical safety report annexes the relevant exposure scenarios to the SDS (Art. 31(7)). Downstream users and distributors carry them forward [1][2].

  • Cost and timing: free of charge, on paper or electronically, no later than the first supply (Art. 31(8)) [2].

  • Updates: "without delay" when any of these happens (Art. 31(9)) [2]:

    • new hazard or risk-management information becomes available;
    • an authorisation is granted or refused;
    • a restriction is imposed.

    The revised version, marked "Revision: (date)", goes free of charge to everyone supplied in the preceding 12 months. Updates after registration must include the registration number.

General Annex II rules [3]

  • The content must be consistent with the registration and the chemical safety report. It must state which nanoforms it covers.
  • It must let employers assess workplace risk under the Chemical Agents Directive 98/24/EC.
  • A competent person prepares it, and the supplier must ensure that person is trained, including refresher training.
  • Use plain language with no jargon or acronyms. Statements such as "harmless", "may be dangerous" or "safe under most conditions of use" are banned.
  • The compilation or revision date goes on page 1, with an indication of which version is replaced. Changes are flagged in Section 16.
  • Length should match the hazard. Every page is numbered ("page 1 of 3" or "Continued on next page"), and no subsection may be left blank.

Key section-level requirements

  • Section 1 [4]:
    • the UFI, if it is shown on the SDS;
    • identified uses and uses advised against;
    • the supplier's full address, phone number, and an email address for the competent person;
    • an emergency number (the national advisory body's number can be enough), with any limits on its availability stated.
  • Section 2 [5]:
    • the CLP classification, matching the supplier's C&L Inventory notification or registration;
    • pictograms, signal word, H- and P-statements;
    • PBT/vPvB and endocrine-disruptor status (for mixtures, for each such substance at ≥0.1 %);
    • hazards that don't lead to classification, such as dust explosion.
  • Section 3 [6][7]:
    • specific concentration limits, M-factors and ATEs where available;
    • for mixtures, listed substances with exact percentages or ranges in descending order;
    • listing thresholds are set by Table 1.1, for example ≥0.1 % for Carc. 1A/1B/2, ≥0.01 % for sensitiser Cat. 1A, ≥1 % for STOT. Substances with EU workplace exposure limits, and PBT/vPvB/Candidate List/endocrine-disruptor substances at ≥0.1 %, are also listed.
  • Section 8: glove material, thickness and breakthrough time; respirator filter type; references to Regulation (EU) 2016/425 and CEN standards [8].
  • Section 9: a mandatory list of properties with units and methods; if a property is missing or doesn't apply, give the reason [9].
  • Sections 11 and 12: endocrine-disrupting effects; ecotoxicity, persistence and bioaccumulation for each Section 3 substance [10][11].
  • Sections 14 and 15: bulk transport under IMO instruments; Seveso, authorisation and restriction status; whether a chemical safety assessment was done.

US: OSHA Hazard Communication Standard, 29 CFR 1910.1200(g)

Taken from the OSHA standard page:

  • Who: manufacturers and importers must obtain or develop an SDS for each hazardous chemical. Employers must have one in the workplace for each hazardous chemical they use.
  • Language and order: English, with 16 sections in the set order. A sub-heading with no relevant information is marked to say so.
  • Updates: significant new hazard or protection information is added within three months.
  • Shipments: the SDS goes with the initial shipment and the first shipment after an update.
  • Workplace access: employers keep copies readily accessible to employees on every shift.
  • 2024 amendment: in effect since 19 July 2024. The compliance deadline for substances was 19 May 2026. For mixtures it is 19 November 2027, and until then the 2023 version may be followed.

Canada: WHMIS, Hazardous Products Regulations (HPR)

  • Format: the Schedule 1 headings, in order, each preceded by its item number. If information isn't available or doesn't apply, the SDS must say so. Sections 12 to 15 may be left without their specific content (s. 4) [12].
  • Schedule 1 content [13][14]:
    • Section 1: initial supplier identifier and emergency number;
    • Section 3: chemical name, CAS number and concentration of health-hazard ingredients;
    • Section 16: date of the latest revision.
  • Language: both English and French, either as one bilingual SDS or two unilingual parts (s. 6.2) [15].
  • Significant new data: for 90 days, a sale or import can go ahead with the existing SDS plus a document listing the changes and the date the data became available (s. 5.12) [16].
  • Products mixed before use: if the instructions call for combining the product with others and that creates new hazards, those must also be covered (s. 4.1) [17].
  • Health professionals: suppliers must give SDS information to health professionals who request it for emergency diagnosis or treatment (s. 6) [18].

Approach: I read the in-force consolidated REACH text and the current Canadian Hazardous Products Regulations, and took the US rules from OSHA's own standard page. I didn't cover GB REACH, other national rules or ECHA's SDS guidance; I can add any of these, or the Annex II sections not summarised here, for the market you're supplying.

Q.02

How many sections does an SDS need?

An SDS has 16 sections. In the EU, REACH Article 31(6) says the safety data sheet "shall be dated and shall contain the following headings", and lists them as items 1 to 16 [1]:

  1. Identification of the substance/mixture and of the company/undertaking
  2. Hazards identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/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
  16. Other information

The other two markets covered in my last answer also use 16 sections:

  • US: OSHA's Hazard Communication Standard (29 CFR 1910.1200(g)) requires 16 sections in a set order. A sub-heading with no relevant information must be marked to say so (OSHA standard page).
  • Canada: Under WHMIS, the SDS uses the Schedule 1 headings of the Hazardous Products Regulations, in order, each preceded by its item number. Sections 12 to 15 may be left without their specific content (s. 4) [12].

Approach: I read Article 31 in the in-force consolidated REACH text (11 May 2026). The US and Canadian points come from the OSHA page and the Hazardous Products Regulations I cited in my previous answer.

Q.03

Is the format different in the EU and US?

The headings are the same in both markets: 16 sections in the same order, titled almost identically. What differs is how the sections are laid out. The EU fixes numbered sub-headings and treats every section as mandatory. The US lists required content for each section but lets you arrange it freely, and Sections 12 to 15 are optional.

Where they match

  • 16 headings in a fixed order. In the EU, Article 31(6) requires the SDS to be dated and to carry the 16 headings [1]. OSHA's Appendix D (29 CFR 1910.1200) uses the same 16 headings, from 1 "Identification" to 16 "Other Information" (OSHA Appendix D).
  • Missing information must be stated. The EU says an SDS "shall not contain blank subsections" (Annex II, 0.4) [19]. OSHA says that where no relevant information exists for a subheading, the SDS "shall clearly indicate that no applicable information is available" (OSHA Appendix D).

Where they differ

PointEU (REACH Annex II)US (OSHA HCS Appendix D)
Sub-headingsFixed, numbered sub-headings are mandatory (1.1 to 1.4, 2.1 to 2.3, and so on to 15.2). In Section 3 you include only 3.1 (substances) or 3.2 (mixtures), whichever applies [3]No numbered sub-headings. All the specified content must be in each section, but "not... in any particular order within each section"
Sections 12 to 15 (ecological, disposal, transport, regulatory)Mandatory, with set sub-headings, for example 12.1 to 12.7, which include 12.5 PBT/vPvB and 12.6 endocrine disruption; 14.1 to 14.7; 15.1 to 15.2 [3]"May be included in the SDS, but are not mandatory." Only Sections 1 to 11 and 16 are required
Section 11Split into 11.1 (CLP hazard classes) and 11.2 (other hazards) [3]One section covering health effects, routes of exposure, acute and chronic effects, and carcinogenicity
Section 16Must include where changes were made in a revision, a legend of abbreviations, key literature references, the classification method used for mixtures, the full text of H/P statements, and training advice [20][3]Date the SDS was prepared or last changed
Page layoutEvery page, annexes included, is numbered and marked "page 1 of 3" or "Continued on next page" / "End of safety data sheet". Length should match the hazard (0.3) [19]No page-numbering rule in Appendix D
Dating and versionsCompilation date on page 1. A revised SDS is marked "Revision: (date)" and states which version it replaces (0.2.5) [19]Preparation or revision date goes in Section 16
AnnexesExposure scenarios are annexed where a chemical safety report exists (0.1.2) [19]No equivalent
LanguageAn official language of each Member State where the product is supplied [1]English (OSHA 1910.1200)

The practical result is that a US SDS cannot be used in the EU as it stands. It has to be rebuilt to the Annex II numbered sub-headings, with Sections 12 to 15 completed, the EU page and revision markings added, and the text translated. An EU-format SDS can generally be laid out to meet OSHA's format rules, but its content still has to meet US requirements, such as OSHA hazard classification and US exposure limits in Section 8.

Approach: I read REACH Annex II in the in-force consolidated text of 11 May 2026. The OSHA Hazard Communication Standard isn't in the datasets I can search, so the US points come from OSHA's official pages for 1910.1200 and Appendix D.

Q.04