Additive manufacturing has revolutionised the way machine components, prototypes, and even medical prosthetics are made.However, before a 3D printer produces a finished object, it operates with chemical mixtures – filaments, photopolymer resins, or sintering powders.

This raises a practical question: do users of 3D printers need to comply with the CLP Regulation and hold Safety Data Sheets (SDS) for these materials?And once the object is printed – is it still considered a chemical product?

3D Printing Materials as Chemical Products

 

From the perspective of the CLP Regulation, consumables used in 3D printing – such as resins, powders, and filaments – are substances or mixtures.Therefore, they fall under Regulation (EC) No. 1272/2008 (CLP) and Regulation (EC) No. 1907/2006 (REACH), just like paints, adhesives, or detergents.

This means that the manufacturer or importer of such a material must:

• perform a hazard classification,

• label the product in accordance with CLP,

• provide a Safety Data Sheet (SDS) where required,

• register substances under REACH if they meet the tonnage thresholds and are not exempt (as is the case for polymers).

 

In practice, acrylic, epoxy, and photopolymer resins almost always require full CLP classification and an SDS.The situation may differ for thermoplastic filaments such as PLA, PETG, or ABS.

When Is an SDS Required for a Filament?

 

Filaments are typically solid products with a low exposure potential and are chemically composed of polymers – substances that are generally not classified as hazardous (unlike the monomers used to make them).

According to Article 31 of REACH, a Safety Data Sheet is not required if:

• the mixture is not classified as hazardous under CLP,

• it does not contain hazardous substances above specified thresholds,

• it does not contain substances of very high concern (SVHC).

 

This means that most filaments do not require an SDS, as long as they do not contain additives (such as plasticisers, pigments, or reinforcing fibres) that alter the classification, or unreacted monomers.Nevertheless, some suppliers still choose to provide an SDS to facilitate communication in the supply chain – to document that the product is non-hazardous and to manage customer expectations more effectively.

🧱 Is a Printed Object Still a Chemical Product?

 

Once 3D printing is complete – regardless of the technology used – the material changes its nature.The filament or resin is no longer a mixture but becomes an article within the meaning of REACH.

What does this mean?

 

An article is an object whose shape, surface, or design determine its function to a greater extent than its chemical composition.Therefore, a finished 3D print is no longer a chemical product, and it is not subject to CLP classification or SDS requirements.

🔍 Exceptions and Situations Where Obligations May Still Apply

 

1. Articles Intentionally Releasing Substances

 

If a printed object is designed to intentionally release a substance (e.g. a fragrance, lubricant, or corrosion inhibitor), legal obligations under REACH may arise.

2. Emissions During Use

 

Some printed objects may inadvertently emit substances, such as unreacted monomers, volatile organic compounds (VOCs), or photoinitiators – particularly in the case of incompletely cured photopolymer resins.In such cases, the safety of use should be evaluated, especially if the article:

• comes into contact with food,

• comes into contact with skin,

• is used in toys, medical devices, or laboratory settings.

 

3. SVHCs in Articles

 

If the printed object contains a substance of very high concern (SVHC) in a concentration above 0.1% w/w, the following obligations may apply:

• Information duty (Article 33 of REACH) – providing information to recipients,

• Notification to the SCIP database, if the article is placed on the EU market.

 

Examples include materials reinforced with carbon fibre, containing plasticisers, or pigments with SVHC components.

Safe Use of 3D Printing Materials

 

Industrial users, universities, and laboratories should be aware that 3D printing materials can be a source of chemical exposure.

The Safety Data Sheet – where required – provides key information on:

• necessary protective measures (ventilation, gloves, goggles),

• toxicological and physicochemical properties,

• safe storage and disposal recommendations.

 

In the case of resin printers, it is particularly important to avoid skin contact with uncured resin and to prevent inhalation of vapours generated during photopolymerisation.

CLP and 3D Printing in Hobby Applications

 

Home or hobbyist 3D printing does not exempt suppliers from CLP obligations.Every chemical material placed on the market must be labelled in accordance with CLP, even when sold to consumers.

This means that containers of resins or powders must display the correct pictograms, H- and P-statements, and supplier contact details, along with all other CLP-required label elements.

What Does This Mean in Practice?

 

📦 For manufacturers and importers:

• Filaments may be exempt from the SDS requirement only if they do not meet the criteria of Article 31 REACH.

• For resins, powders, and photopolymer materials, an SDS is usually mandatory.

• All packaging must bear CLP-compliant labelling.

 

👷 For industrial users:

• Always request an SDS or a formal statement of exemption from your supplier.

• Verify that labels match the SDS information.

• Ensure appropriate protective measures and ventilation at the workplace.

 

🏠 For consumer users:

• Pay attention to pictograms and label information.

• Avoid printing in unventilated spaces – emissions from molten filaments may contain substances harmful to health.

 

Summary

 

3D printing materials are chemical products under the CLP Regulation, but documentation obligations depend on their composition and intended use. A PLA filament may not require a Safety Data Sheet, whereas an acrylic resin almost certainly does. The key lies in assessing whether the product meets REACH criteria.Once printed, the object is typically an article, not a mixture – but the materials used to produce it remain subject to chemical compliance obligations.