Safety Data Sheets: validity and regulatory compliance

Safety Data Sheets (SDS) are concise documents that provide all the chemical, physical, toxicological, and environmental characteristics of a substance or mixture, along with its classification.

SDS are mandatory if the preparations/mixtures are classified as hazardous according to EC Regulation 1272/2008 (CLP).

Currently, and until June 1, 2017, SDS for hazardous mixtures may comply with more than one regulatory reference.

According to Article 2 of Regulation 2015/830 (subject to Article 31, paragraph 9, of Regulation (EC) No. 1907/2006): “Safety data sheets provided to recipients before June 1, 2015, may continue to be used and do not need to comply with the annex of the aforementioned regulation until May 31, 2017.”

As a result, it is still possible to find SDS on the market with different update dates, but they are still considered valid.

For clarity, we outline the different possibilities you may encounter:

• SDS compliant with Regulation 2015/830: SDS issued or revised after June 1, 2015 (CLP classification and labeling);
• SDS compliant with Annex I of Regulation 453/2010: for products already on the market before June 1, 2015, classified (and labeled) according to DPD (the SDS will report both CLP and DPD classification only in section 3.2);
• SDS compliant with Annex II of Regulation 453/2010 (as amended): for products already on the market before June 1, 2015, classified according to CLP (the SDS will report both DPD and CLP classifications in sections 2.1 and 3.2 – while section 2.2, related to the label, must reflect the CLP classification).

Therefore, SDS do not have an “expiration date.” The only requirement they must meet is to be updated according to the latest applicable regulations. This update must be made immediately by the supplier if new information becomes available related to classification, risk management measures, or specific authorizations/restrictions.