With the growing number of obligations arising from the REACH and CLP Regulations, proper communication of chemical safety information is becoming increasingly important. One of the key tools in this process is the extended Safety Data Sheet, known as eSDS.

This is not just an expanded version of the standard Safety Data Sheet (SDS) — it is also a document that ensures detailed communication on the safe use of substances throughout the entire supply chain.

What exactly is an eSDS?

An extended Safety Data Sheet is a Safety Data Sheet supplemented with Exposure Scenarios (ES).

These scenarios are developed in accordance with the REACH Regulation and describe the conditions under which a substance can be used safely for humans and the environment.

In practice, an eSDS therefore contains not only basic hazard information, but also detailed recommendations on how to handle the substance safely, including technical controls and personal protective measures — going beyond the scope of a standard SDS.

Not every substance requires an eSDS — this obligation applies only in specific cases.

Legal basis

The obligation to prepare an extended Safety Data Sheet arises from Article 31(7) of the REACH Regulation:

"Any actor in the supply chain who is required to prepare a chemical safety report according to Articles 14 or 37 shall place the relevant exposure scenarios (including use and exposure categories where appropriate) in an annex to the safety data sheet covering identified uses and including specific conditions resulting from the application of Section 3 of Annex XI.

Any downstream user shall include relevant exposure scenarios, and use other relevant information, from the safety data sheet supplied to him when compiling his own safety data sheet for identified uses.

Any distributor shall pass on relevant exposure scenarios, and use other relevant information, from the safety data sheet supplied to him when compiling his own safety data sheet for uses for which he has passed on information according to Article 37(2).”

In simplified terms, this means that any supply chain actor required to prepare a Chemical Safety Report (CSR) must attach the relevant exposure scenarios covering identified uses of the substance to the Safety Data Sheet.

When is an eSDS required?

An extended Safety Data Sheet must be prepared and provided to the recipient if all of the following conditions are met:

✅ The substance has been registered in quantities of at least 10 tonnes per year per registrant.
✅ The substance is classified as hazardous under the CLP Regulation or has been identified as:
– PBT (Persistent, Bioaccumulative and Toxic),
– vPvB (very Persistent and very Bioaccumulative).
✅ A Chemical Safety Assessment (CSA) has been conducted for the substance.

In such cases, the supplier must attach the exposure scenarios as annexes to the Safety Data Sheet and provide the complete document to the product recipients.

What does an Exposure Scenario include?

An Exposure Scenario is a practical description of the safe use of a substance under specific conditions.

It typically includes:
• identification of the type of use (e.g. industrial, professional, consumer),
• description of the operations (e.g. filling, transferring, diluting, spraying),
• technical parameters such as pressure, temperature, and physical state,
• recommendations for ventilation, filtration, and emission control,
• personal protective measures (gloves, masks, closed systems),
• DNEL and PNEC values,
• Risk Characterization Ratios (RCR) showing the level of safety for each use.

Thanks to this, the user can implement specific risk management measures at the workplace to maintain exposures at safe levels.

Obligations of downstream users

If your company receives an eSDS from a supplier, you are required to verify whether your use of the product is covered by the provided Exposure Scenario.

In practice, this involves the following steps:

1. Check compliance – confirm whether your use of the product is included in the Exposure Scenario.
2. Implement safety measures – follow the protective measures described in the eSDS.
3. React if not covered – if your use is not included, you can:
   • inform your supplier about your use,
   • prepare your own Chemical Safety Assessment,
   • modify your use or switch suppliers.

In practice – what does an eSDS look like?

Extended Safety Data Sheets can be quite lengthy — often dozens or even hundreds of pages.
The annexes containing Exposure Scenarios are usually highly detailed and require expert interpretation.

Analyzing an eSDS allows you to:
• ensure that the substance is used in compliance with REACH requirements,
• prepare for potential inspections by competent authorities,
• improve workplace chemical safety,
• avoid administrative penalties or civil liability.

Expert support

An extended Safety Data Sheet is not just a formal requirement — it is a key element of effective chemical risk management.

If you are unsure whether your products require an eSDS, or you don’t know how to interpret the Exposure Scenarios you received — it is worth consulting with chemical safety experts.