Safety Data Sheet Format: 16 Sections Explained

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 Maker, ATE Calculator

---

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

Below is what each heading carries, with the regulation’s own numbering. Each row links to a full breakdown of that section: the complete subsection checklist under REACH Annex II, OSHA Appendix D and UN GHS Annex 4 side by side, where the EU and US genuinely diverge, and the errors that get that section rejected. The whole set is indexed at SDS sections: all 16 explained.

§	Heading	What it carries
1	Identification	Product identifier, supplier details, recommended and advised-against uses, and the emergency telephone number. In the EU also the UFI and, where relevant, the word “nanoform”.
2	Hazard(s) identification	The classification, then the label elements that follow from it — signal word, pictograms, H-statements, P-statements — plus other hazards that do not result in classification.
3	Composition / information on ingredients	The hazardous ingredients, their identifiers and their concentration or range, with specific concentration limits, M-factors and ATE values where they exist.
4	First-aid measures	Route-by-route instructions a non-professional can follow, the symptoms to expect acutely and with delay, and when specialist treatment is needed.
5	Fire-fighting measures	Suitable and — the half most often dropped — unsuitable extinguishing media, the hazardous combustion products, and the protection firefighters need.
6	Accidental release measures	Personal precautions split between non-emergency personnel and trained responders, environmental precautions, and containment and clean-up methods.
7	Handling and storage	Precautions for safe handling, the conditions and incompatibilities that govern storage, and any specific end uses.
8	Exposure controls / personal protection	The occupational exposure limits and biological limit values in force where the sheet is supplied, DNELs and PNECs, engineering controls, and PPE item by item.
9	Physical and chemical properties	The eighteen basic properties (a) to (r) after the 2020/878 restructuring, then further data relevant to the physical hazard classes.
10	Stability and reactivity	Reactivity, chemical stability, possible hazardous reactions, conditions to avoid, incompatible materials and hazardous decomposition products.
11	Toxicological information	Renamed by 2020/878 to “Information on hazard classes as defined in Regulation (EC) No 1272/2008” plus “Information on other hazards” — the data behind every health hazard class.
12	Ecological information	Aquatic toxicity, persistence and degradability, bioaccumulation, mobility, PBT and vPvB results and — new in 2020/878 — endocrine disrupting properties.
13	Disposal considerations	Waste treatment methods for the product, its residues and its contaminated packaging, and the properties that affect how it can be treated.
14	Transport information	UN number or ID number, proper shipping name, transport hazard class, packing group, environmental hazards, and maritime bulk transport under IMO instruments.
15	Regulatory information	Authorisation, restriction, SVHC status, major-accident thresholds and national provisions — plus whether a chemical safety assessment has been carried out.
16	Other information	The revision date and version, what changed, the abbreviation key, the full text of the H-statements referenced elsewhere, and the data sources.

⚠ Sections 12 to 15 are not enforced by OSHA. Ecology, disposal, transport and wider chemical law fall to the EPA, the Department of Transportation and other agencies, not to the Hazard Communication Standard. All sixteen are mandatory under REACH Annex II, and in practice nearly every commercial US sheet carries all sixteen so that one document can travel.

---

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:

1. 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.
2. Blank fields in Section 9 — physical/chemical properties left empty rather than marked “not applicable” or “no data available” with a reason.
3. Stale revision date in Section 16 — references to current regulations elsewhere in the SDS but a Section 16 date that predates them.
4. 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.
5. UN number or shipping name in Section 14 that doesn’t match mode — the same substance can have different ADR/IMDG/IATA classifications.
6. 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.
7. 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.
8. Trade name / product code mismatch between SDS, physical label, and purchase order.
9. Auto-translation errors when issuing multilingual SDS — pictogram captions distorted, OEL units mistranslated, P-statements dropped.
10. 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.

---

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
• SDS Authoring Software: What It Does and What It Costs — published prices, and how software compares with outsourcing the sheets.
• SDS sections: all 16 explained — the section-by-section reference this article summarises: subsection checklists for the EU, US and UN texts, and a jump into the same section on any of our substance pages
• SDS library — see the 16-section structure applied to real substances: harmonised classification, storage verdicts, and transport data for 100+ chemicals

---

Sources

1. 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
2. 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
3. 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
4. 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
5. 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
6. 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.