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The 2023 SDS Compliance Checks in the EU are Still Ongoing

from CIRS by

On February 15, this year, the European Chemicals Agency (ECHA) published an announcement that national enforcement authorities have started compliance inspections (REF-11) on safety data sheets (SDS) for chemicals sold on the EU market.

This project was prepared in 2022 and the main purpose is to evaluate whether SDSs have been updated in compliance with the new requirements of Annex II of REACH. These inspections will be carried out throughout the year as a unified enforcement project. The results will be made public in 2024.

An SDS is used to deliver the safety data of chemicals in the supply chain and to ensure workers and professionals can use substances and mixtures in a safe way. The health of users may not be assured if the information is lacking or inaccurate. During the inspection REF-2 (2013), flawed information on safety data sheets was found to be as high as 52%.

EU regulation COMMISSION REGULATION (EU) 2020/878 was implemented on January 1, 2023. Some important revisions to the requirements of SDSs in this regulation are listed below:

  1. Nanomaterials and their concrete forms should be listed in the SDS if substances and components in mixtures meet the definition of nanomaterials;
  2. UFI codes need to be written on the SDS if the mixture is under duty of CLP Article 45 and Annex VIII;
  3. Information on endocrine disruptors should be shown in the SDS. For example, whether endocrine disruptors are contained, and what are the negative impacts on human health and the environment?;
  4. Special concentration limits of some hazard categories were changed, which may have an effect on the representation of ingredients in section 3 of the SDS. This part of old SDSs should be re-checked;
  5. If the product is classified as a desensitized explosive, this new hazard classification should be added in SDS. Other information on the desensitized explosives is also needed;
  6. Special concentration limits, M-factor, or ATE values of some substances or mixtures (if they have them) should be listed on the SDS;
  7. Columns of physical and chemical properties were added in section 9 of the SDS; and
  8. Information requirements of section 14 were also updated, e.g. Judgment result of marine pollutants is necessary to state in this part.

Duty holders need to start self-examination of their SDSs immediately in response REF-11 in EU and keep running business activities. SDS non-compliance with the new regulation must be revised without any delay.

CIRS Group can provide professional service for SDS revision, UFI generation and many other related projects.

If you need any assistance or have any questions, please contact us via

Further Information

HSA Ireland is Checking Compliance of SDSs


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