A Safety Data Sheet (SDS) is a fundamental document in the handling of chemicals, providing users with information about hazards, safe use, and risk management measures.

In practice, the question often arises: Does a Safety Data Sheet have an expiration date? If not, is there any need to update the SDS at all?

In this article, we explain when and under what circumstances an update is necessary and what obligations are placed on suppliers of substances and mixtures.

Does a Safety Data Sheet Have an Expiration Date?

Formally speaking, a Safety Data Sheet does not have a set expiration date. Regulation (EC) No 1907/2006 (REACH) does not specify an automatic expiry date for the document.

However, the absence of an "expiration date" does not mean that the SDS can remain unchanged for many years. Regulations require that the supplier keeps the SDS up to date in line with the latest information on hazards, risk control methods, and applicable regulations. Therefore, depending on different factors, updating the SDS may be required at varying frequencies.

When Is an SDS Update Required?

According to Article 31(9) of the REACH Regulation, an SDS must be updated in the following cases:

• New information on hazards or ways to safely use the substance or mixture;

• Authorization granted for the use of a substance subject to authorization;

• Restrictions imposed on the use of the substance or mixture (e.g., under REACH or CLP regulations).

In each of these situations, the updated version of the document must be promptly provided to all recipients who received the product within the past 12 months.

For most chemical products on the market, the most important and most common reason for updating the SDS is the first point above: the emergence of new hazard information. New information on hazards can result, among others, from:

• Updates of raw material SDSs from our suppliers;

• Changes in the composition of our product;

• Changes in regulations that affect the CLP classification of the substances and mixtures we use.

The above-mentioned changes do not occur on a fixed schedule and are highly dependent on the company’s activities and the range of substances used—the more substances, the greater the chance that one of these factors will trigger a need for an update. Therefore, updating the SDS is not periodic but arises from specific changes related to particular substances or mixtures. It is essential to monitor regulatory developments and your substance and raw material portfolio to ensure you always apply the most up-to-date information.

What Does This Mean in Practice?

🔹 The lack of an automatic expiration date does not exempt suppliers from the responsibility to maintain SDSs up to date. Monitoring legislative changes (e.g., CLP updates) and scientific data is essential.

🔹 A reliable SDS update should occur whenever classifications change, new regulations come into force, or new hazard information becomes available.

🔹 Large enterprises usually perform regular SDS reviews—preferably at least once every 1–3 years. Even if no significant changes have occurred, such audits help ensure that the documentation remains compliant.

🔹 In certain industries (e.g., chemical, pharmaceutical), regular SDS updates are a standard practice, also required during ISO or occupational health and safety system audits.

Why Is Updating Safety Data Sheets So Important?

• Risk minimization – up-to-date information helps protect workers’ health and the environment.

• Legal compliance – an outdated SDS can result in administrative penalties.

• Building the company’s image – current documentation demonstrates the supplier's professionalism and responsibility.

Important: Providing updated SDSs is mandatory even if the recipient has not requested a new version!

Summary

Safety Data Sheets do not have a formal expiration date, but their updating is an obligation arising from chemical law regulations. Regular reviews and prompt responses to legislative changes are crucial to ensuring safety and legal compliance.

Remember: If your company places chemical substances or mixtures on the market, you should regularly verify the status of your SDSs and implement updates where required.

FAQ – Frequently Asked Questions About SDS Updates

Do I have to update the Safety Data Sheet every year?

No. Updates are mandatory only in specific cases (new hazards, regulatory changes). However, a review every 1–3 years is good practice.

Does a change in the company's contact details require an SDS update?

Yes. Any change in the supplier's name, address, or contact details must be reflected in a new version of the SDS.

What are the consequences of not updating the SDS?

An outdated SDS can lead to fines, administrative orders, and even liability for potential damages.

✅ Checklist: When Do You Need to Update a Safety Data Sheet?

✅ SDS update is required when:

• 🔄 The hazard classification of a substance or mixture changes (due to a change in composition, raw material, or regulations);

• 🧪 New scientific or technical information emerges (e.g., new toxicity studies);

• ✅ Authorization is granted for a substance;

• ❌ Restrictions are imposed on a substance or mixture (e.g., REACH restrictions);

• 🏢 There is a change in the supplier’s identification data (name, address, contact details).

Remember: The updated SDS must be sent to all recipients of the product from the past 12 months!

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