On the market, you can find many products with the same function but differentiated by color or fragrance variants. Examples include paints, detergents, or scented candles. In many cases, products of a given type are based on the same chemical “base,” with final differences in appearance resulting only from the addition of various pigments or fragrance compositions.

Intuitively, we might therefore expect that products belonging to one “family” will be very similar to each other, which raises the question: do I need to have a separate Safety Data Sheet (SDS) for each product in such a group? Or is it possible to prepare one SDS for the entire set of such products?

Naturally, the prospect of reducing the amount of required documentation is very attractive from a business perspective, as it not only lowers compliance costs but also potentially simplifies the management of SDSs. And indeed, this option does exist: in some cases, in line with the requirements of Regulation 2020/878/EU, it is possible to prepare a single SDS for a group of products. However, we must ensure that the information provided in the SDS is applicable to each product covered by the document.

Conditions for preparing one Safety Data Sheet for a group of products

Developing a common SDS for a “product family” must not violate the provisions of the REACH Regulation, in particular Annex II. Several basic conditions must therefore be met:

• Identical CLP classification – the primary purpose of an SDS is to inform the user about hazards associated with the product. To fulfill this purpose, products grouped under one SDS must share the same hazard profile, which in turn determines the risk management measures, such as technical conditions, storage methods, or personal protective equipment.

• The same (or very similar) chemical composition – differences can only concern minor components present in negligible amounts, which do not affect the information provided in the SDS. As a general rule, if a separate SDS were created for each product in the group, Section 3 would look the same in each case if concentration ranges were applied. It is also essential that the substances listed in Section 3 are present in every product included in the group.

• Identical labeling – there should be no differences here, since Section 2.2 of the SDS reflects the labeling elements that must appear on the product label.

In practice, this means that for products grouped together, all essential information presented in the SDS must be identical, from classification and composition to labeling, protective measures, and recommendations for safe use.

In practice:

We place structural plasters on the market that differ only in shade. The individual color variants are achieved by adding small amounts of pigments that are not classified as hazardous. The presence of these pigments does not require disclosure in the SDS. This means that, from a regulatory perspective, the products are identical with respect to SDS requirements, and therefore a single document can be prepared for the group.

Roadblocks for creating a grouped Safety Data Sheet

Conversely, the following conditions constitute formal obstacles to preparing a single SDS for a product family:

• Different hazard classifications – this affects the SDS content and requires separate documents.

• Significantly different composition – if Section 3 would look different for each product.

• Different labeling elements – for example, variations in supplementary label information such as EUH208 statements. In such cases, each SDS must describe labeling specific to the product. If such differences occur, it clearly indicates that a common SDS is not possible.

It is possible to find SDSs where several products of differing composition are included in one document, with the authors differentiating elements of labeling or composition in Sections 2 and 3 – for example, depending on the fragrance composition used.

However, this approach is not correct, as an SDS must present hazard information in a clear, unambiguous way, leaving no room for doubt. Experience shows that such grouping of products is often negatively assessed by authorities and may be challenged during inspections.

In practice:

A client manufactures scented candles based on soy wax, which is not classified as hazardous. Food-grade colorants are used, which also have no CLP classification and do not affect the hazard profile of the candle. At this stage, grouping is still possible.

However, the candles contain different fragrance compositions, the addition of which requires that all candles are classified the same way (as skin sensitizers with H317 and hazardous to the aquatic environment with H411). In this respect, grouping would still seem possible.

Yet, due to the differing compositions of the fragrances, Section 3 of the SDS would need to list numerous substances, some of which would be present only in certain candles and not in others. This means that such products cannot be covered by a single SDS, as Section 3 should reflect the actual composition of each product individually.

Practical aspects of preparing Safety Data Sheets for product groups

• Documentation can be optimized by preparing one SDS for a group of products, provided the conditions outlined in this article are met.

• This solution can reduce costs and save time on updates – one SDS can cover several products. However, the reverse can also occur: if the composition of just one product in the group changes in a way that excludes it from the common SDS, it must be separated, a new document prepared for it, and the existing SDS updated for the remaining products.

• Documentation must not be simplified at the expense of compliance – an SDS cannot conceal significant differences in hazards or uses. The document must be clear, precise, and accurately reflect the actual composition of the product, without listing substances not present in it.

• In case of doubt, it is advisable to consult an experienced SDS author.

Conclusion

It is possible to prepare a single Safety Data Sheet covering several products, but only if the differences between them are negligible and do not affect classification, hazards, or intended use. This approach is convenient for products with nearly identical composition, but it always requires careful evaluation and full compliance with REACH and CLP regulations.