How to Properly Deliver a Safety Data Sheet?
The Safety Data Sheet (SDS) is a key document used to communicate information on hazards, safe use, and control measures related to chemical substances. However, creating the SDS is not enough – it is equally important to understand how and when the SDS should be delivered to the recipient.
Obligation to Deliver the Safety Data Sheet – When, How and to Whom?
According to Article 31 of Regulation (EC) No 1907/2006 (REACH):
- The SDS must be provided free of charge, in paper or electronic form, no later than the date of the first delivery of the substance or mixture.
- This obligation applies to suppliers: manufacturers, importers, downstream users, and distributors in the supply chain who supply the substance or mixture in the EU.
- The SDS must be provided in the official language of the country where the product is placed on the market.
Format of SDS Delivery – Paper or Electronic?
The ECHA guidance states:
"It should be noted however that in this context the wording “shall be provided” is to be understood as a proactive duty on the supplier to actually deliver the SDS (and every required update) rather than just make it available passively, for example on the internet or reactively by delivering it on request."
Permissible delivery formats for the SDS include:
✅ Paper printout
✅ Electronic format, e.g. PDF sent by email or a download link to the SDS. For the latter solution, there are additional requirements:
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the link must be direct and point to a specific SDS;
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the link must be reliable and active, and should ideally never expire;
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the customer must proactively receive updated versions of the link (if it changes);
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the customer must be proactively informed about any SDS updates;
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access to the SDS via link should not be restricted (e.g., by requiring login).
❌ Simply making the SDS available on a website without informing the recipient is not sufficient – the customer must be notified and have easy access to the document.
What About SDS Updates?
If the SDS has been changed (e.g. updated classification, protective measures, toxicological data), then:
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The revised version must be immediately delivered to all recipients who received the product in the past 12 months;
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The method of delivering the updated SDS remains the same as for a new SDS provided for the first time;
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The new version must include the date of the update and indicate which sections have been changed.
How to Deliver the SDS in Practice?
🟩 When delivering a product for the first time, make sure to include the SDS – preferably as a PDF attached to the invoice or shipping confirmation email.
🟩 Implement a document management system for SDSs – so you can prove that the SDS was delivered (e.g., email archives, proof of receipt).
🟩 Ensure language consistency – the SDS must be in the language of the country where the product is sold.
🟩 Be ready to respond quickly to changes – updated classification or toxicological data means the SDS must be re-delivered.
Summary
Delivering a Safety Data Sheet is not just a formality – it is a legal obligation under the REACH Regulation. A well-organised SDS distribution system helps avoid errors and proves compliance during inspections.
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