A Safety Data Sheet (SDS) is the standardized 16-section document that travels with a hazardous chemical from manufacturer to end user. It communicates physical, health, and environmental hazards, safe handling and storage practices, emergency response procedures, regulatory information, and disposal guidance. The SDS is the central document underpinning chemical hazard communication across every major jurisdiction worldwide — from the United States and the European Union to Canada, Australia, China, and beyond.
The format you see today — exactly 16 sections in a fixed order — originated with the UN Globally Harmonized System (GHS) and was implemented in the US through OSHA HCS 2012, replacing the older Material Safety Data Sheet (MSDS). In the EU, REACH Article 31 and Annex II govern SDS requirements; the current version is Commission Regulation (EU) 2020/878, applicable since January 2021.
This guide is for compliance specialists, EHS managers, SDS authors, and downstream users working with hazardous chemicals under REACH, CLP, OSHA HCS, WHMIS, or any other GHS-aligned framework. It explains the 16 sections in detail, the major regulatory frameworks, the latest OSHA HCS 2024 SDS deadlines (extended in January 2026 by Federal Register notice 91 FR 1695), retention and update obligations, who is qualified to author an SDS, and what ECHA’s REF-11 enforcement project found about EU compliance quality.
At a glance
- Document type: Standardized 16-section hazard communication document
- Other names: SDS (current), MSDS (deprecated since OSHA HCS 2012; still heavily searched), GHS SDS, Material Safety Data Sheet
- Origin: UN GHS Annex 4; harmonized format adopted globally since 2003
- EU framework: REACH Article 31 + Annex II (Commission Regulation (EU) 2020/878, in force 1 January 2021)
- US framework: OSHA Hazard Communication Standard (29 CFR 1910.1200) Appendix D — HCS 2024 deadlines extended 15 January 2026
- Canada framework: Hazardous Products Regulations under WHMIS 2015
- Retention — EU: Minimum 10 years (REACH Article 36)
- Retention — US: 30 years for employee exposure records (29 CFR 1910.1020)
- ECHA compliance audit (REF-11, 2023): 35% non-compliance across 2,528 SDS in 28 countries
- Language: Official language(s) of each Member State / English in US / English & French in Canada
Background: from MSDS to SDS
The Safety Data Sheet, as it exists today, is the product of two decades of international standardization. Before the UN GHS, chemical hazard documentation was fragmented. Different countries used different formats with different content requirements. A US Material Safety Data Sheet (MSDS), a European chemical safety sheet, and a Japanese product information sheet for the same substance could differ in section order, hazard descriptions, and even the data they prioritized — creating compliance burden, supply chain confusion, and inconsistent worker protection.
The UN GHS, first published in 2003, defined a single 16-section format in its Annex 4. National regulators progressively aligned their frameworks with this standard:
- 2006 (EU) — Regulation (EC) No 1907/2006 (REACH) established Article 31 requiring an SDS for hazardous substances and mixtures, with Annex II defining the format
- 2010 (EU) — Commission Regulation (EU) No 453/2010 first aligned Annex II with the UN GHS
- 2012 (US) — OSHA published HCS 2012 (the “Right-to-Know” update), formally retiring the term MSDS and adopting the 16-section SDS aligned with GHS Revision 3
- 2015 (Canada) — Hazardous Products Regulations under WHMIS 2015 adopted the 16-section SDS aligned with GHS Revision 5
- 2015 (EU) — Commission Regulation (EU) 2015/830 updated Annex II for further GHS alignment
- 2020 (EU) — Commission Regulation (EU) 2020/878, the current version of Annex II, added new requirements for nanoforms, endocrine-disrupting properties, Unique Formula Identifier (UFI) codes, specific concentration limits (SCLs), M-factors, and acute toxicity estimates (ATEs)
- 2024 (US) — OSHA HCS 2024 (Federal Register 89 FR 44144, 20 May 2024) updated Appendix D to align with GHS Revision 7; compliance dates initially set for January 2026 onward
- 2026 (US) — OSHA published a Final Rule on 15 January 2026 (Federal Register 91 FR 1695) extending all HCS 2024 compliance dates by four months
The term MSDS remains in widespread informal use despite being officially deprecated by OSHA in 2012 and superseded across all major jurisdictions. Search volume data shows “msds” still attracts substantial monthly queries — a reminder that legacy terminology persists even after regulatory transitions.
Who must provide an SDS
SDS obligations attach to legal entities placing hazardous chemicals on the market. The actor categories are consistent across jurisdictions, though specific terminology varies:
Manufacturers and importers are the primary duty holders. They classify substances and mixtures, author the SDS based on available scientific data, and supply the SDS to direct customers free of charge.
Distributors and downstream users must verify that received chemicals come with a compliant SDS and pass it on to their own customers. Under REACH, downstream users formulating their own mixtures must author their own SDS for the formulated product, drawing on supplier SDSs and their own use information.
Employers in the US must maintain copies of SDSs for all hazardous chemicals in their workplace and ensure employee access during work shifts. Under OSHA HCS, “access” means physically reachable during the shift — paper binders, digital systems, and cloud platforms all qualify, but the system must remain available even if Wi-Fi or power fails.
Only Representatives (OR) are EU-based entities appointed by non-EU manufacturers to assume REACH and CLP obligations on their behalf — see the REACH Registration Step-by-Step guide for the full OR mechanism under Article 8. This is increasingly common for chemicals imported into the EU from Asia, North America, and the UK post-Brexit.
An SDS is required whenever:
- A substance or mixture is classified as hazardous under CLP, OSHA HCS, WHMIS, or equivalent
- A mixture contains a hazardous substance above specified concentration thresholds, even if the mixture itself does not meet a hazard classification
- The substance is PBT, vPvB, PMT, vPvM under REACH criteria (regardless of CLP classification)
- A substance is on the REACH Candidate List of Substances of Very High Concern (SVHC) above 0.1% w/w
- Specific exposure or use restrictions apply under national legislation
The SDS must be provided in the official language(s) of each Member State or country where the product is sold. The supplier bears the translation cost. ECHA estimates a multinational supplier may need to maintain 20-plus language versions of a single SDS for EU and EEA markets alone.
The 16 sections: overview
The UN GHS-defined 16-section structure is mandatory across all major jurisdictions. Section numbers and headings are identical worldwide; the specific content requirements vary slightly by jurisdiction (REACH Annex II, OSHA Appendix D, WHMIS HPR, etc.).
| # | Section | Purpose |
|---|---|---|
| 1 | Identification | Product name, supplier, emergency contact, UFI |
| 2 | Hazards identification | Classification, label elements, other hazards |
| 3 | Composition / information on ingredients | Hazardous components, concentration ranges, SCLs |
| 4 | First-aid measures | Symptoms, response by exposure route |
| 5 | Firefighting measures | Suitable extinguishing media, special hazards |
| 6 | Accidental release measures | Spill containment, environmental precautions |
| 7 | Handling and storage | Safe practices, incompatibilities |
| 8 | Exposure controls / personal protection | Occupational exposure limits, PPE |
| 9 | Physical and chemical properties | Appearance, flash point, vapor pressure, etc. |
| 10 | Stability and reactivity | Conditions to avoid, incompatible materials |
| 11 | Toxicological information | Health effects, route of exposure, ED properties |
| 12 | Ecological information | Aquatic and terrestrial toxicity, persistence, ED-ENV |
| 13 | Disposal considerations | Waste codes, contaminated packaging |
| 14 | Transport information | UN number, proper shipping name, hazard class |
| 15 | Regulatory information | Authorization, restrictions, national rules |
| 16 | Other information | Date of preparation, revision history, abbreviations |
Sections 1, 2, and 3 carry the most regulatory weight — they communicate identity, hazard classification, and composition, which downstream users and emergency responders consult first. Sections 12, 13, 14, and 15 are technical references but become critical in regulatory audits and compliance checks.
For an in-depth walkthrough of every section’s content requirements under UN GHS, OSHA HCS, REACH, and WHMIS, see Safety Data Sheet Format: 16 Sections Explained.
The 16 sections in detail
Section 1 — Identification. Product identifier (chemical name, code, batch identifier), recommended use and restrictions, supplier name and address, emergency phone number. Under REACH 2020/878, the Unique Formula Identifier (UFI) — a 16-character alphanumeric code generated from the EU VAT number and an internal product reference — must be shown for hazardous mixtures subject to Poison Centre Notification.
Section 2 — Hazards identification. GHS classification (hazard classes and categories), label elements (signal word, hazard pictograms, H-statements, P-statements), and “other hazards” — including PBT, vPvB, PMT, vPvM, and endocrine-disrupting properties under REACH 2020/878 and CLP-aligned criteria.
Section 3 — Composition / information on ingredients. For substances: chemical identity, concentration, CAS and EC numbers. For mixtures: hazardous components above concentration thresholds, classifications, specific concentration limits (SCLs), M-factors for aquatic toxicity, and acute toxicity estimates (ATEs).
Section 4 — First-aid measures. Response actions by exposure route — inhalation, skin contact, eye contact, ingestion. Symptoms and delayed effects. Notes for physicians where specific antidotes apply.
Section 5 — Firefighting measures. Suitable and unsuitable extinguishing media, specific hazards arising from the chemical (combustion products, decomposition), and advice for firefighters (protective equipment, special procedures).
Section 6 — Accidental release measures. Personal precautions, protective equipment, emergency procedures, environmental precautions, methods and materials for containment and cleanup.
Section 7 — Handling and storage. Precautions for safe handling, conditions for safe storage (including incompatibilities), and specific end uses where covered by a chemical safety report.
Section 8 — Exposure controls / personal protection. Occupational exposure limit values (OEL, DNEL, PNEC), engineering controls (ventilation, containment), and personal protective equipment by exposure route.
Section 9 — Physical and chemical properties. Physical state, color, odor, melting point, boiling point, flash point, vapor pressure, density, solubility, partition coefficient, autoignition temperature, decomposition temperature, viscosity, explosive properties, and oxidizing properties.
Section 10 — Stability and reactivity. Reactivity, chemical stability, possibility of hazardous reactions, conditions to avoid, incompatible materials, hazardous decomposition products.
Section 11 — Toxicological information. Acute toxicity, skin corrosion/irritation, eye damage/irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, STOT-SE, STOT-RE, aspiration hazard, and (since REACH 2020/878) endocrine-disrupting properties affecting human health.
Section 12 — Ecological information. Aquatic toxicity (acute and chronic), persistence and degradability, bioaccumulative potential, mobility in soil, results of PBT and vPvB assessment, endocrine-disrupting properties affecting the environment, and other adverse effects.
Section 13 — Disposal considerations. Waste treatment methods, waste codes (European Waste Catalogue), and information on disposal of contaminated packaging.
Section 14 — Transport information. UN number, UN proper shipping name, transport hazard class, packing group, environmental hazards (marine pollutant), special precautions for users, and transport in bulk according to relevant codes (ADR, RID, IMDG, IATA-DGR).
Section 15 — Regulatory information. Safety, health, and environmental regulations specific to the substance or mixture — including authorization status under REACH Title VII, restrictions under REACH Annex XVII, national regulations, chemical safety assessment results.
Section 16 — Other information. Date of preparation of the SDS or its latest revision, key to abbreviations and acronyms, key literature references, classification methods used, list of relevant H-statements and P-statements in full.
Regulatory frameworks
EU — REACH Article 31 + Annex II. Commission Regulation (EU) 2020/878 amended Annex II of REACH (Regulation (EC) No 1907/2006), introducing the current SDS format. Applicable since 1 January 2021. The transition period for legacy-format SDSs ended 31 December 2022. Key 2020/878 additions: UFI code in Section 1.1, nanoform information across Sections 1-12, endocrine-disrupting property information in Sections 2.3, 11.2, and 12.6, mandatory inclusion of specific concentration limits, M-factors, and ATEs in Section 3, and granular exposure scenario references. The CLP Regulation (EC 1272/2008) supplies the classification and labeling content that appears in Sections 2 and 14 of the SDS. See the EU CLP pillar guide for the classification framework.
US — OSHA HCS 2024. The Hazard Communication Standard (29 CFR 1910.1200) requires SDSs through paragraph (g) and specifies content in Appendix D. HCS 2024 (Federal Register 89 FR 44144, 20 May 2024) aligned the standard with UN GHS Revision 7 and revised Appendix D content for Sections 2, 3, 9, and 11. Original compliance dates required manufacturer, importer, and distributor SDS updates for substances by 19 January 2026 and for mixtures by 19 July 2027. On 15 January 2026, OSHA published a Final Rule (Federal Register 91 FR 1695) extending all HCS 2024 compliance dates by four months:
- Substances — manufacturers, importers, distributors: 19 May 2026
- Substances — employers (workplace updates and training): 20 November 2026
- Mixtures — manufacturers, importers, distributors: 19 November 2027
- Mixtures — employers: 19 May 2028
OSHA invoked the “good cause” exception under the Administrative Procedure Act, bypassing formal notice-and-comment rulemaking because of the imminence of the original 19 January 2026 deadline. Between the publication of HCS 2024 and the applicable compliance date, suppliers may use the 2012 HCS format, the 2024 HCS format, or both. See the OSHA HCS pillar guide for full framework coverage.
Canada — WHMIS 2015. The Hazardous Products Regulations (HPR) under the Hazardous Products Act govern SDS content for suppliers. The HPR was most recently amended on 4 January 2023, aligning with UN GHS Revision 7 plus selected elements of Revision 8. SDSs must be available in both English and French.
Australia — Model WHS Regulations. Safe Work Australia’s model WHS regulations require an SDS in 16-section format aligned with GHS Revision 7, fully effective from 1 January 2023. State and territory work-safety regulators enforce.
Other jurisdictions. China (GB/T 17519 and GB 30000), Japan (JIS Z 7253), South Korea (MoEL system with K-REACH and MSDS submission), Brazil (ABNT NBR 14725:2023, GHS Rev 7), and dozens of other markets all use the 16-section format with country-specific deviations in language, exposure limits, and regulatory references in Section 15.
For the global GHS framework underlying every national SDS rule, see the UN GHS pillar guide.
Language requirements
SDS language is a recurring source of compliance failure for cross-border suppliers. The rules:
European Union. The SDS must be supplied in the official language(s) of each Member State where the product is placed on the market. France requires French, Germany requires German, Italy requires Italian. Multilingual states such as Belgium require multiple languages. The Member State may permit additional languages alongside the official one but cannot waive the official-language requirement. ECHA estimates that compliant cross-EU coverage requires 24-plus language versions when EEA and accession candidate countries are included.
United States. OSHA HCS requires SDSs to be supplied in English. Employers may maintain copies in additional languages where the workforce requires them. Section 5 of paragraph (g) explicitly states the SDS must be in English.
Canada. WHMIS HPR requires SDSs to be available in both English and French. Both versions must contain identical information; a single bilingual SDS or two separate English and French SDSs are both acceptable.
Translation responsibility. The translation cost falls on the supplier in all major frameworks. Inaccurate or incomplete translations are treated as non-compliance and have been a recurring finding in ECHA enforcement projects.
Update triggers
An SDS is not a static document. Updates are required whenever:
New hazard information becomes available. New scientific data altering classification, new exposure data altering OELs, new toxicological findings — all trigger an update. Under REACH Article 31, the supplier must provide the updated SDS to all recipients of the substance or mixture in the previous 12 months, free of charge.
Classification changes. A new harmonized classification under CLP Annex VI (an ATP), a self-classification revision, or alignment with a new GHS revision all require SDS updates within specific timeframes.
Authorization changes. A new authorization granted (or refused) under REACH Title VII, or a new restriction added to REACH Annex XVII, must be reflected in Section 15.
Composition changes. Reformulating a mixture changes Section 3 content and may change Sections 2, 11, and 12 classifications. The UFI must be regenerated when composition changes meaningfully.
6-month rule (OSHA). When new and significant information becomes available, OSHA HCS gives chemical manufacturers, importers, and employers six months to add the information to labels and SDSs (29 CFR 1910.1200(g)(5)). Chemicals shipped after the six-month window must reflect the new information.
Version control discipline. Section 16 must show the date of preparation or latest revision. Maintaining a clear revision history is essential for both regulatory inspection and downstream user traceability. ECHA’s REF-11 enforcement project found that 27% of inspected SDSs had data-quality deficiencies traceable to incomplete version control.
Retention requirements
Retention obligations differ between EU and US frameworks and continue to confuse many suppliers.
European Union — 10 years. REACH Article 36 requires retention of all REACH-relevant documents, including all SDS versions ever supplied, for at least 10 years after the last manufacture, import, supply, or use of the substance or mixture. The obligation applies equally to manufacturers, importers, downstream users, and distributors. If a business closes or is sold during the retention period, the obligation transfers to the successor or liquidator. Documents must be available to ECHA and national competent authorities on request.
United States — 30 years (with nuance). OSHA HCS itself does not specify an SDS retention period for the SDS as a document. The widely-cited “30-year rule” comes from a separate standard — 29 CFR 1910.1020 (Access to Employee Exposure and Medical Records), which classifies SDSs as employee exposure records and requires those records to be kept for 30 years. Two implications:
- Employers must retain SDSs (or substitute records identifying chemical, location, and dates of use) for 30 years from the last date of employee exposure, not from the last date the chemical was in the workplace.
- If formulation changes, both old and new SDS versions must be retained for the full 30 years — they represent different exposure profiles.
Practical guidance. Suppliers operating in both markets default to 30 years (the longer obligation) to satisfy both. EU-only suppliers may operate on the 10-year minimum, but most compliance professionals retain longer for traceability and potential litigation defense.
Authoring an SDS: who is qualified
REACH Article 31 requires an SDS to be prepared by a competent person, defined in REACH Annex II Section 0.2.3 as a person who, taking into account their training, experience, and continuous learning, has the knowledge to prepare the relevant SDS sections. There is no specific certification mandated under REACH, and OSHA HCS likewise does not require formal credentials. The relevant skills set:
- Toxicology and exposure assessment
- Hazard classification under UN GHS, CLP, OSHA HCS, and WHMIS
- Regulatory framework knowledge across target markets
- Workplace exposure limit databases (OELs, DNELs, PNECs)
- Transport regulations (ADR, RID, IMDG, IATA-DGR)
- Translation accuracy and regulatory equivalents across languages
Professional credentials. While not legally required, some authoring professionals hold credentials such as the Society for Chemical Hazard Communication’s certifications, the Board of Certified Safety Professionals (CSP/CHST) qualifications, or REACH-specific competency certificates issued by national authorities.
Authoring approaches. Three common paths:
- In-house authoring. Larger chemical manufacturers maintain dedicated regulatory affairs teams handling SDS authoring across products and markets.
- Contract authoring services. Specialized consultancies prepare SDSs for clients across multiple jurisdictions, often charging per-SDS plus regulatory updates.
- SDS authoring software. Platforms maintain regulatory phrase libraries (such as the Cefic ESCom standard phrase catalogue), Annex VI integration, multilingual templates, and version-control workflows. The market includes both standalone authoring tools and integrated EHS suites.
The choice depends on portfolio size, target markets, and update frequency. A US-only supplier with 20 products may sustainably author in-house. A multinational placing 500 mixtures on 27 EU markets typically combines software platforms with consultancy for complex cases.
For practical mixture classification supporting SDS Section 3 content, the ATE Calculator on ghssymbols.com computes acute toxicity estimates from Annex VI and component data.
Common errors and enforcement
ECHA’s Enforcement Forum REF-11 project examined SDS compliance in 2023 across 28 EU and EEA countries. Inspectors reviewed 2,528 SDSs to assess conformity with the new requirements introduced by REACH 2020/878. Results published in December 2024:
Headline numbers.
- 87% of SDSs complied with the new 2020/878 format
- 35% showed non-compliance in specific content requirements
- 81% of suppliers had active procedures to update and share SDSs with clients
Most frequent failures.
- 67% of SDSs requiring nanoform information failed to provide it
- 48% of SDSs for ED substances missed required endocrine-disrupting property information
- Missing or incorrectly placed UFI codes (Section 1.1)
- Missing authorization numbers (Section 2.2)
- Incorrect classification and labelling in Sections 2.1 and 2.2
- Missing SCLs, M-factors, and ATEs in Section 3
- 16% missing required exposure scenarios
- 27% with data quality deficiencies — incorrect hazard identification, composition, or exposure controls
Enforcement measures used. Written advice (69%), administrative orders (11%), fines (11%), criminal complaints (6%). The 17% of cases involving administrative orders, fines, or criminal complaints reflects meaningful regulatory action, not just guidance.
Follow-on enforcement. ECHA’s Enforcement Forum is now running REF-12 (imported chemicals — checking documentation at the EU border) and REF-13 (online chemical sales — verifying classification, labelling, and packaging compliance). Both project SDS data feed into national enforcement authority casebooks through 2026 and 2027.
Key takeaways
- A Safety Data Sheet (SDS) communicates chemical hazards in a standardized 16-section format defined by UN GHS Annex 4 and implemented through REACH, OSHA HCS, WHMIS, and other national frameworks
- MSDS is the deprecated US term replaced by SDS under OSHA HCS 2012; the format change is essentially complete worldwide
- EU current rules: Commission Regulation (EU) 2020/878 amending REACH Annex II, applicable since 1 January 2021, adds nanoform, endocrine-disruptor, UFI, SCL, M-factor, and ATE content requirements
- US current rules: OSHA HCS 2024 (89 FR 44144) — compliance deadlines extended by four months on 15 January 2026 (91 FR 1695). Substances by 19 May 2026 for M/I/D; mixtures by 19 November 2027
- Retention: EU 10 years (REACH Article 36); US 30 years (29 CFR 1910.1020) as employee exposure records
- REF-11 (2023): ECHA inspected 2,528 SDSs across 28 countries — 35% non-compliant, with worst failures in nanoform and ED property reporting
- Authoring: No mandated certification, but “competent person” expertise required across toxicology, classification, regulatory frameworks, and translation accuracy
Articles in this pillar
The SDS pillar covers the document format and its global regulatory implementations. Current cluster article:
- Safety Data Sheet Format: 16 Sections Explained — detailed walkthrough of every section’s content requirements under REACH, OSHA HCS, and WHMIS
Sister pillars covering adjacent regulatory frameworks:
- UN GHS — the global framework
- EU CLP Regulation — classification feeding into SDS Sections 2 and 14
- OSHA HCS — US implementation with 16-section SDS Appendix D
- REACH — EU chemical registration and the legal basis for SDS Article 31
- SVHC — Substances of Very High Concern triggering SDS Section 15 updates
Tools to act on this content:
- ATE Calculator — compute acute toxicity estimates for SDS Section 3
- GHS Label Constructor — generate CLP-compliant labels matching SDS Section 2
- Substance Database — CAS-indexed CLP Annex VI classifications for SDS authoring
Sources
- ECHA — Guidance on the Compilation of Safety Data Sheets (Version 4.0, December 2020)
- EUR-Lex — Commission Regulation (EU) 2020/878 amending REACH Annex II
- EUR-Lex — Regulation (EC) No 1907/2006 (REACH) Article 31 and Article 36
- OSHA — Hazard Communication Standard 29 CFR 1910.1200 Appendix D
- Federal Register — OSHA HCS Final Rule 89 FR 44144 (20 May 2024)
- Federal Register — OSHA HCS Compliance Date Extension 91 FR 1695 (15 January 2026)
- OSHA — HCS 2024 Compliance Date Extension Notice
- OSHA — 29 CFR 1910.1020 Access to Employee Exposure and Medical Records
- ECHA — REF-11 Project Report on Safety Data Sheets (December 2024)
- ECHA — REACH Article 31 Safety Data Sheets
- Health Canada — Hazardous Products Regulations (WHMIS HPR)
- Safe Work Australia — Safety Data Sheets — Model Code of Practice
- CCOHS — Safety Data Sheet (SDS) WHMIS 2015
- UNECE — Globally Harmonized System of Classification and Labelling of Chemicals (Annex 4)
- BAuA — Safety Data Sheets technical guidance