A safety data sheet (SDS) follows the same 16-section structure whether it travels from a German chemical manufacturer to a Swiss reseller, gets written by a US chemical importer, or lands on the desk of an Indian downstream user. The format is set by Annex 4 of the UN Globally Harmonized System (GHS) and then adopted into law by OSHA’s Hazard Communication Standard at 29 CFR 1910.1200 Appendix D and by the EU REACH Regulation in Annex II as amended by Regulation (EU) 2020/878. Despite small regional differences in mandatory content, the 16 headings and their numbering are identical worldwide.
This article walks every SDS section, what each must contain, where the EU and US diverge, and the most common errors that get safety data sheets rejected during compliance audits. If you author or review safety data sheets — as a regulatory affairs specialist, EHS manager, downstream user assessing supplier documents, or compliance professional preparing for export — keep this as a working reference next to your draft.
At a glance
- Format origin: UN GHS Annex 4, first published in 2003, currently in Revision 11 (2025)
- EU rule: REACH Annex II as amended by Commission Regulation (EU) 2020/878, mandatory since 31 December 2022
- US rule: OSHA Hazard Communication Standard 29 CFR 1910.1200 Appendix D, in force since 1 June 2015
- Mandatory sections: sections 1–11 and 16 in the US; all 16 sections in the EU
- Length: typically 8–15 pages; nanoform substances and REACH extended SDS often run longer
- Language: English in the US; the official language of each Member State where the product is placed on the EU market
- Related tools on this site: GHS Label Constructor, ATE Calculator on ghssymbols.com
Background: how 16 sections became the global standard
Before 2003, safety data sheet content varied wildly between countries. The United States required Material Safety Data Sheets (MSDS) under OSHA’s 1994 Hazard Communication Standard, but the rule prescribed information categories without fixing sections, headings, or ordering. Europe used the SDS term but with its own format under Directive 91/155/EEC. Canada’s WHMIS, Australia’s NOHSC code, and Japan’s JIS Z 7250 each defined their own templates. A US manufacturer exporting a hazardous substance to four countries often had to author four document versions.
The UN Sub-Committee of Experts on the GHS published the first edition of the GHS “purple book” in 2003, with Annex 4 setting out a standardized 16-section SDS format. The structure has remained stable across all eleven revisions since: each new edition refines sub-section content (such as new hazard classes or test methods) but never changes the section count or headings.
Adoption followed the typical GHS pattern of national transposition with regional adaptations. The US OSHA aligned its Hazard Communication Standard with GHS Revision 3 in the 2012 final rule (HCS 2012), with full SDS enforcement from 1 June 2015. The EU first transposed the GHS SDS structure through REACH Annex II in 2007, then amended it three times — through Commission Regulations (EU) 453/2010, 2015/830, and 2020/878 — to align with successive GHS revisions and to add EU-specific content like the Unique Formula Identifier (UFI) and endocrine-disruptor disclosure. The latest amendment, Regulation (EU) 2020/878, became mandatory for all EU SDS authored from 31 December 2022 onward.
Two recent regulatory events triggered the current wave of SDS revisions: OSHA’s HCS 2024 final rule (covered in our OSHA HCS 2024 Changes article) and CLP ATP 22 (covered in our CLP ATP 22 article). Both update content inside specific SDS sections without changing the 16-section count.
How the 16 sections are organized
The headings are not in arbitrary order. They cluster by the questions a reader asks during an emergency, during routine handling, and during regulatory review:
| Sections | Purpose group | Read by |
|---|---|---|
| 1–4 | Rapid response: identity, hazards, ingredients, first aid | Anyone in 30 seconds |
| 5–8 | Workplace handling: fire, spill, storage, exposure controls | EHS, line operators |
| 9–11 | Technical and scientific data | Toxicologists, formulators |
| 12–15 | Environmental, lifecycle, transport, regulatory | Regulators, logistics, waste |
| 16 | Revision date, abbreviations, references | Compliance auditors |
Reading top to bottom, an emergency responder gets the first 8 sections quickly. A compliance officer auditing the document jumps to Section 16 first to check the revision date and version history.
The 16 sections, one by one
Section 1 — Identification
The opening section identifies the substance or mixture and its supplier.
Required content:
- Product identifier — the same trade name, product code, or chemical name that appears on the label
- Other means of identification — synonyms, CAS number, EC number, formula
- Recommended use and restrictions — intended applications, plus statutory or supplier-recommended restrictions
- Supplier details — full name, address, phone number, and email of the manufacturer, importer, or other responsible party
- Emergency phone number — required by OSHA HCS to be available; a 24-hour emergency line is standard practice
EU specifics under Regulation (EU) 2020/878: if the SDS covers a hazardous mixture with a UFI assigned under Annex VIII to CLP, the UFI must appear in subsection 1.1. If the substance includes one or more nanoforms, the word “nanoform” must appear in the product identifier.
Practical tip: the trade name, product code, and revision date in Section 1 must match the purchase order and the physical label byte-for-byte. Typos here trigger automatic compliance rejections.
Section 2 — Hazard(s) Identification
Section 2 communicates the hazard classification and the label elements derived from it.
Required content:
- 2.1 Classification of the substance or mixture under GHS/CLP/HCS rules — every hazard class and category
- 2.2 Label elements — pictogram(s), signal word (“Danger” or “Warning”), all hazard (H) statements, and all precautionary (P) statements
- 2.3 Other hazards — including PBT (persistent, bioaccumulative, toxic) and vPvB (very persistent, very bioaccumulative) substances; under EU 2020/878, also endocrine-disrupting properties at concentrations of 0.1% by weight or higher
US specifics under OSHA HCS: the US recognizes a “Hazards Not Otherwise Classified” (HNOC) category for hazards that do not fit any GHS class but where the manufacturer has evidence of harm. HNOC information goes in Section 2. The 2024 HCS final rule introduced new sub-sections covering chemicals under pressure and refined simple-asphyxiant disclosure — see our OSHA HCS 2024 Changes article for transition deadlines.
UN GHS Rev 11 update: Annex 11 of the latest revision provides specific guidance on simple asphyxiants in Section 2. Details in UN GHS Rev 11 Changes.
Practical tip: the hazard classification in Section 2 must align mathematically with the ingredient mixture in Section 3. Auditors run consistency checks on this pair first.
Section 3 — Composition / Information on Ingredients
Section 3 lists what is actually in the product.
Two sub-sections:
- 3.1 Substances — for single-substance SDS: chemical name, CAS, EC, REACH registration number where available, identification of impurities and stabilizing additives that affect classification
- 3.2 Mixtures — for mixtures: each ingredient that is hazardous, listed with concentration or concentration range, plus identifiers and CLP classification
EU specifics under 2020/878: Section 3 must now also include, where applicable, the Specific Concentration Limit, M-factor, Acute Toxicity Estimate, and particle characteristics for each listed ingredient. Concentration thresholds for when an ingredient must be listed have been tightened.
Practical tip: the ATE values you put here are what your downstream user will plug into mixture classification software. The ATE Calculator on ghssymbols.com shows how those numbers flow into final mixture classification.
Section 4 — First-Aid Measures
Section 4 tells responders what to do for each route of exposure.
Sub-sections:
- 4.1 Description of first-aid measures — by route: inhalation, skin contact, eye contact, ingestion
- 4.2 Most important symptoms and effects — both acute and delayed
- 4.3 Indication of immediate medical attention and special treatment needed
Practical tip: match the wording to the hazard category. A Skin Corr. 1A substance demands “rinse with running water for at least 15 minutes” — not the generic “rinse if irritation occurs.” Reviewers check this consistency between Section 2 classification and Section 4 wording.
Section 5 — Fire-Fighting Measures
Section 5 supports fire response decisions.
Sub-sections:
- 5.1 Suitable extinguishing media (and unsuitable media — water on a metal fire is a deadly mistake)
- 5.2 Special hazards arising from the substance or mixture — toxic combustion products (HF from fluorinated polymers, HCN from nitrogen-containing compounds, dioxins from chlorinated organics)
- 5.3 Advice for firefighters — PPE level (typically self-contained breathing apparatus and full protective gear), evacuation distances
Section 6 — Accidental Release Measures
Section 6 covers spill response.
Sub-sections:
- 6.1 Personal precautions, protective equipment, emergency procedures
- 6.2 Environmental precautions — preventing release to drains, waterways, soil
- 6.3 Methods and material for containment and clean-up — absorbents (vermiculite, sand, dedicated chemical sorbent), neutralization where applicable, decontamination of contaminated equipment
Section 7 — Handling and Storage
Section 7 addresses normal operating conditions.
Sub-sections:
- 7.1 Precautions for safe handling — ventilation, grounding for flammables, avoiding incompatibilities, hygiene practices
- 7.2 Conditions for safe storage — incompatible materials, ventilation requirements, container materials, temperature, humidity, sunlight
- 7.3 Specific end uses — for substances with REACH-registered exposure scenarios, this sub-section either points to the extended SDS annex or summarizes the operational conditions
Practical tip: the storage incompatibility list here must match the storage matrix on the substance’s hazard reference page. Cross-check against /hazards/[cas]/ storage data on ghssymbols.com.
Section 8 — Exposure Controls / Personal Protection
Section 8 quantifies exposure limits and specifies PPE.
Sub-sections:
- 8.1 Control parameters — Occupational Exposure Limits (OEL/PEL/TLV in the US, EU IOELV and Member State limits in Europe, plus REACH Derived No-Effect Levels (DNEL) and Predicted No-Effect Concentrations (PNEC))
- 8.2 Exposure controls — engineering controls (local exhaust ventilation, closed systems), individual protection measures (eye, skin, respiratory PPE), with glove material recommendations including breakthrough time when relevant
Practical tip: if the substance has a “skin” notation in OEL tables, declare it explicitly here. Missing skin notation is a frequent omission on imported SDS.
Section 9 — Physical and Chemical Properties
Section 9 lists measured or predicted physical and chemical properties.
Sub-sections:
- 9.1 Information on basic physical and chemical properties — physical state, color, odor, melting/freezing point, boiling point, flash point, evaporation rate, flammability, explosive limits, vapor pressure, vapor density, density, solubility, partition coefficient (log Kow), auto-ignition temperature, decomposition temperature, viscosity
- 9.2 Other information — under EU 2020/878, this sub-section must include specific physical-hazard endpoints from CLP Annex I Part 2 (such as those used for Aerosols or Self-Heating substances classification)
Format change in 2020/878: the basic properties in 9.1 may now appear in any order and any format, as long as all required properties are present. Authors no longer need to maintain a fixed order if a different sequence reads more naturally.
Practical tip: never leave a property blank. State “not applicable” with a reason (“substance is solid at room temperature — no flash point”) or “no data available” with a justification. Empty fields fail audits.
Section 10 — Stability and Reactivity
Section 10 covers chemical behavior under various conditions.
Sub-sections:
- 10.1 Reactivity — general reactivity profile
- 10.2 Chemical stability — stable under normal conditions? polymerization risks?
- 10.3 Possibility of hazardous reactions — including conditions that trigger them
- 10.4 Conditions to avoid — heat, light, mechanical shock, static, specific gas atmospheres
- 10.5 Incompatible materials — strong oxidizers, strong acids, water, specific metals
- 10.6 Hazardous decomposition products — what forms when the substance burns, hydrolyzes, or photolyses
Section 11 — Toxicological Information
Section 11 documents health hazards in technical detail.
Sub-section 11.1: information on toxicological effects, organized by hazard class:
- Acute toxicity (oral, dermal, inhalation LD50/LC50; ATE for the mixture)
- Skin corrosion/irritation
- Serious eye damage/irritation
- Respiratory or skin sensitization
- Germ cell mutagenicity
- Carcinogenicity
- Reproductive toxicity
- STOT (single exposure)
- STOT (repeated exposure)
- Aspiration hazard
Sub-section 11.2 (NEW under EU 2020/878): information on other hazards, primarily endocrine-disrupting properties for human health.
Practical tip: the LD50 and LC50 numbers here flow into mixture classification calculations. For mixtures, the ATE values from supplier SDS power downstream classification — see how on the ATE Calculator. For substances, the toxicology entry on ghssymbols.com /hazards/[cas]/ mirrors the data the supplier should report.
Section 12 — Ecological Information
Section 12 covers environmental fate and effects.
Sub-sections:
- 12.1 Toxicity — aquatic acute and chronic categories, terrestrial toxicity where relevant
- 12.2 Persistence and degradability — biodegradation half-life, hydrolysis
- 12.3 Bioaccumulative potential — log Kow, BCF
- 12.4 Mobility in soil — Koc value, leaching potential
- 12.5 Results of PBT and vPvB assessment
- 12.6 Endocrine-disrupting properties (NEW under EU 2020/878) — when applicable, addressing effects on non-target organisms
- 12.7 Other adverse effects — ozone depletion potential, photochemical ozone creation potential, global warming potential
OSHA position: OSHA does not enforce Section 12 in the US — environmental matters fall under EPA jurisdiction — but most US authors include it for international coherence.
Section 13 — Disposal Considerations
Section 13 advises on safe disposal.
Sub-section 13.1: waste treatment methods, including:
- Description of waste residues and information on safe handling
- Disposal methods for the substance/mixture and any contaminated packaging
- Reference to applicable waste codes (EU European Waste Catalogue codes; US RCRA hazardous waste codes; national equivalents elsewhere)
Practical tip: disposal advice that violates the user’s local waste regulations is one of the most common audit findings. A US-authored SDS recommending sewer disposal of a substance classified as hazardous waste under RCRA — or under the EU EWC — fails the local rule and exposes the supplier.
Section 14 — Transport Information
Section 14 covers transport classification and dangerous-goods compliance.
Sub-sections:
- 14.1 UN number — the four-digit identifier from the UN Model Regulations
- 14.2 UN proper shipping name
- 14.3 Transport hazard class(es) — including subsidiary risks
- 14.4 Packing group (I, II, or III, where applicable)
- 14.5 Environmental hazards — marine pollutant flag for sea transport
- 14.6 Special precautions for user
- 14.7 Maritime transport in bulk — specific information for IBC Code, IMSBC Code, IGC Code where the cargo is shipped in bulk
Mode-specific differences: the same substance can have slightly different requirements under road (ADR in Europe, US DOT 49 CFR), rail (RID), sea (IMDG), and air (IATA DGR) regulations. A correctly authored Section 14 either notes that classification is identical across modes or breaks out the differences.
Cross-check: GHS labels and ADR/DOT transport diamonds are different graphics serving different audiences. The GHS vs ADR Inspector shows how a single substance can carry both label systems on its outer packaging.
Section 15 — Regulatory Information
Section 15 captures additional regulatory status not already covered elsewhere.
Sub-sections:
- 15.1 Safety, health, and environmental regulations specific to the substance or mixture
- 15.2 Chemical safety assessment — for REACH-registered substances above 10 tonnes per year, an indication of whether a CSA has been carried out
EU specifics: REACH Authorization (Annex XIV inclusion), REACH Restriction (Annex XVII), inclusion on the SVHC Candidate List for endocrine disruption or other concerns, and CLP Annex VI harmonised classification status. Recent CLP ATP 22 entries — covered in our CLP ATP 22 article — must propagate into Section 15 for affected substances.
US specifics: TSCA inventory status, SARA Title III Sections 302 and 313 reportable categories, CERCLA reportable quantities, California Proposition 65 listing for known carcinogens or reproductive toxicants, and state right-to-know lists.
Other regions: national inventory status (Canada DSL/NDSL, Australia AICIS, Japan ENCS, Korea KECI, China IECSC) — see the country-by-country breakdown in UN GHS Implementation by Country.
OSHA enforcement note: OSHA does not enforce Section 15 in the US, but the substance classifications referenced often come from US authorities anyway, and downstream users expect them to be present.
Section 16 — Other Information
Section 16 closes the document with housekeeping data.
Required content:
- Date of preparation or last revision — the most-checked field by auditors
- Indication of changes from the previous version — usually a brief change log
- Glossary or list of abbreviations — LD50, ATE, vPvB, DNEL, PNEC, CSA, BCF, Koc, etc.
- Full text of any H- and P-statement codes referenced in earlier sections
- Training advice where appropriate
- Key references and sources used to compile the data
Practical tip: every time a regulation cited in Sections 2, 3, 11, 12, 14, or 15 changes — including CLP ATPs and OSHA HCS revisions — bump the revision date and append a change-log entry. SDS with revision dates that have not moved despite recent regulatory updates fail audit.
Regional variations: EU vs US vs Asia
The 16 headings are universal, but mandatory content differs across jurisdictions.
EU SDS under REACH Annex II (Regulation (EU) 2020/878)
- Mandatory sections: all 16, every sub-section
- Language: the official language of every Member State where the product is placed on the market — a French SDS does not satisfy a German customer
- Specific additions introduced or reinforced by Regulation (EU) 2020/878:
- UFI (Unique Formula Identifier) in Section 1.1 for hazardous mixtures placed on the EU market
- Nanoform identifier in Section 1.1
- Endocrine-disrupting properties in Sections 2.3, 11.2, and 12.6 (threshold ≥0.1% by weight)
- Specific concentration limits, M-factors, ATE values, and particle characteristics in Section 3
- Bulk maritime sub-section 14.7
US SDS under OSHA HCS (29 CFR 1910.1200 Appendix D)
- Mandatory sections: sections 1–11 and 16. Sections 12–15 may be included but are not enforced by OSHA, since environmental, disposal, transport, and most non-OSHA regulatory matters fall under other federal agencies. Most US suppliers include all 16 anyway.
- Language: English
- Specific features:
- HNOC (Hazards Not Otherwise Classified) disclosed in Section 2
- Recent additions from HCS 2024 (covered in OSHA HCS 2024 Changes): chemicals under pressure as a new physical hazard class, refined simple-asphyxiant criteria, and updated label/SDS provisions phasing in through 2026–2028
- California Prop 65 carcinogen and reproductive-toxicant warnings in Section 15 for products shipped to California
ISO 11014 and Asia
- ISO 11014:2009 is the international standard for SDS preparation. It mirrors the GHS 16-section structure and is adopted as the national SDS standard in some countries (such as South Africa via SANS 11014:2010) where regulators have not directly transposed GHS into chemical legislation.
- China: GB/T 16483-2008, broadly aligned with GHS
- Japan: JIS Z 7253, recently updated to align with GHS Revision 9
- Korea: KOSHA SDS rules under the Industrial Safety and Health Act
- Indonesia, Turkey, Brazil, Mexico, GCC states: each transposes GHS through national instruments — see country-specific entries in UN GHS Implementation by Country
A practical consequence: the same substance shipped from a US manufacturer to subsidiaries in 30 countries typically requires localized SDS — same 16 sections, but country-specific language, OEL tables, regulatory inventories, and waste codes.
MSDS vs SDS: the terminology shift
The acronym “MSDS” — Material Safety Data Sheet — predates GHS. Before 2003, safety data sheets in the US were called MSDS under OSHA’s 1994 Hazard Communication Standard, which required the document but did not prescribe sections, headings, or order. Format varied between suppliers, ingredient disclosure rules differed by state, and toxicology coverage was often patchy. Other regions used their own terms — “fiche de données de sécurité” in France, “Sicherheitsdatenblatt” in Germany — but Europe shifted to the abbreviation “SDS” as part of GHS adoption.
The transition timeline:
- 2003: UN GHS Revision 1 introduced both the 16-section format and the harmonised “Safety Data Sheet” terminology
- 2007: EU REACH Regulation 1907/2006 entered into force; Annex II adopted the SDS term
- 2010–2012: US gradual transition; the term “MSDS” was phased out as suppliers updated documents
- 2012: OSHA HCS 2012 final rule formally adopted “SDS” with the 16-section format
- 2015 (1 June): full US enforcement deadline; from this date, all hazardous chemicals shipped by manufacturers, importers, and distributors required compliant SDS
If you receive a document labelled “MSDS” from a US supplier today, it is non-compliant — request the current SDS in the 16-section format. The same applies to multilingual EU markets: pre-2022 SDS authored under the older Regulation (EC) 2015/830 are no longer permitted; only the 2020/878 format is mandatory now.
For a deeper comparison of MSDS vs SDS structure and a section-by-section migration guide, see the upcoming SDS pillar overview.
Common SDS authoring mistakes
Compliance audits and regulatory inspections surface the same recurring errors:
- Section 2 vs Section 3 mismatch — pictograms and H-statements in Section 2 do not align mathematically with the ingredient mixture in Section 3. Fixing this is the first audit step.
- Blank fields in Section 9 — physical/chemical properties left empty rather than marked “not applicable” or “no data available” with a reason.
- Stale revision date in Section 16 — references to current regulations elsewhere in the SDS but a Section 16 date that predates them.
- Disposal advice in Section 13 that violates local waste codes — frequent on imported SDS that recommend US-style RCRA disposal in a country using EU EWC codes.
- UN number or shipping name in Section 14 that doesn’t match mode — the same substance can have different ADR/IMDG/IATA classifications.
- Missing endocrine-disruptor disclosure in EU SDS — sections 2.3, 11.2, and 12.6 omitted post-2020/878 for substances or mixtures meeting the 0.1% threshold.
- Missing UFI in Section 1.1 — a hazardous mixture placed on the EU market without UFI in Section 1.1 fails the 2020/878 format.
- Trade name / product code mismatch between SDS, physical label, and purchase order.
- Auto-translation errors when issuing multilingual SDS — pictogram captions distorted, OEL units mistranslated, P-statements dropped.
- Revision date not bumped after regulatory change — for example, after CLP ATP 22 added new harmonised classifications in May 2026, every SDS for affected substances should have been republished with an updated Section 15 and a new Section 16 date.
Key takeaways
- Same 16 headings worldwide, different mandatory content — UN GHS Annex 4 fixes the section count and titles; OSHA HCS, REACH Annex II, and national rules layer their own sub-section requirements on top.
- EU vs US split: all 16 sections mandatory in the EU, only sections 1–11 and 16 enforced in the US, but most US authors include sections 12–15 anyway for international coherence.
- Recent EU additions matter: Regulation (EU) 2020/878 added UFI in Section 1.1, nanoform identifier, endocrine-disruptor disclosure across 2.3/11.2/12.6, and particle characteristics in Section 3 — missing any of these makes the SDS non-compliant for the EU market.
- Section 16 is the auditor’s first stop — the revision date and change log signal whether the SDS has kept pace with regulatory updates like HCS 2024 and CLP ATP 22.
- Section 2 ↔ Section 3 consistency is the single most-audited pair; the classification you state must be reproducible from the ingredient mixture you list.
FAQ
What are the 16 sections of an SDS?
The 16 standardized sections, in order, are: (1) Identification, (2) Hazard(s) Identification, (3) Composition / Information on Ingredients, (4) First-Aid Measures, (5) Fire-Fighting Measures, (6) Accidental Release Measures, (7) Handling and Storage, (8) Exposure Controls / Personal Protection, (9) Physical and Chemical Properties, (10) Stability and Reactivity, (11) Toxicological Information, (12) Ecological Information, (13) Disposal Considerations, (14) Transport Information, (15) Regulatory Information, and (16) Other Information. The headings are identical worldwide because they originate from Annex 4 of the UN GHS, then get adopted into law by OSHA’s HCS in the US (29 CFR 1910.1200 Appendix D) and by REACH Annex II in the EU (most recently amended by Regulation (EU) 2020/878).
Are all 16 sections of the SDS mandatory in the United States?
No. OSHA’s Hazard Communication Standard mandates sections 1–11 and section 16. Sections 12 (Ecological Information), 13 (Disposal Considerations), 14 (Transport Information), and 15 (Regulatory Information) may be included on the SDS but are not enforced by OSHA, since those subjects fall under EPA, DOT, or other federal jurisdictions. In practice, almost every commercially available US SDS includes all 16 sections to satisfy international shipping requirements and downstream user expectations. EU SDS under REACH Annex II must include all 16 sections in full.
What is the difference between MSDS and SDS?
MSDS (Material Safety Data Sheet) is the legacy US term that predates GHS adoption. Pre-2012, MSDS format varied between suppliers — there was no required section count or order. SDS (Safety Data Sheet) refers to the modern 16-section format introduced by UN GHS in 2003 and adopted into US law through OSHA’s HCS 2012 final rule, with full enforcement on 1 June 2015. The EU never used “MSDS” — the SDS term has been standard there since REACH took effect in 2007. If you receive a document labelled “MSDS” from a US supplier today, it is non-compliant; request the current SDS in 16-section format.
How often should an SDS be updated?
Whenever new information affects hazard classification, handling, storage, transport, or regulatory status. Trigger events include: new toxicology data on an ingredient; addition of a substance to the SVHC Candidate List or REACH Authorization list; CLP Adaptations to Technical Progress (ATPs) that change harmonised classification — see CLP ATP 22 Changes; UN GHS revisions transposed into local law; HCS amendments such as the HCS 2024 final rule; and supplier formulation changes for mixtures. As a baseline, request the latest revision from suppliers at least annually for critical chemicals, and flag any SDS where Section 16 hasn’t moved in over three years.
Who needs an SDS, and who provides it?
Under OSHA HCS, employers in the US must maintain a current SDS for every hazardous chemical present in the workplace, accessible to employees on every shift. Chemical manufacturers, importers, and distributors are legally required to provide SDS to downstream customers free of charge — typically with the first shipment of a product and whenever an updated version is issued. Under EU REACH, suppliers of hazardous substances and mixtures must provide an SDS to professional and industrial recipients before or with the first delivery, in the official language(s) of every Member State where the product is placed on the market. Consumer-only products are generally exempt, though suppliers often provide SDS voluntarily.
Related articles in this hub
- UN GHS Implementation by Country — country-by-country regulatory status, the ground truth for Section 15 entries
- OSHA HCS 2024 Changes — what HCS 2024 added to Section 2 and the 2026–2028 transition timeline
- UN GHS Rev 11 Changes — Annex 11 simple-asphyxiant guidance and other Section 2 updates
- CLP ATP 22 Changes: Annex VI Updates May 2026 — new harmonised classifications affecting Section 15
Sources
- United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Eleventh revised edition (2025), Annex 4 — Guidance on the Preparation of Safety Data Sheets. Available at: https://unece.org/transport/dangerous-goods/ghs-rev11-2025
- OSHA Hazard Communication Standard, 29 CFR 1910.1200, Appendix D — Safety Data Sheets (Mandatory). US Department of Labor. Available at: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppD
- Commission Regulation (EU) 2020/878 of 18 June 2020 amending Annex II to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Official Journal of the European Union L 203, 26.6.2020, pp. 28–58. Available at: https://eur-lex.europa.eu/eli/reg/2020/878/oj/eng
- ECHA Guidance on the compilation of safety data sheets, Version 4.0, December 2020. European Chemicals Agency. Available at: https://echa.europa.eu/documents/10162/2324906/sds_en.pdf
- ISO 11014:2009 Safety data sheet for chemical products — Content and order of sections. International Organization for Standardization. Available at: https://www.iso.org/standard/55934.html
- Substance classification examples referenced in this article are sourced from the GHSSymbols.com Hazards Database, derived from ECHA CLP Annex VI list of harmonised classifications, last synchronised May 2026.