Although safety data sheets (SDSs) have been required in the chemical industry for many years, recent data shows that the quality of SDS preparation still varies widely. A large-scale inspection conducted in 2023 across the EU has revealed that creating compliant and accurate SDSs remains a challenge for many companies.

What did the SDS inspections reveal?

As part of the REF-11 enforcement project, 2528 safety data sheets for substances and mixtures were reviewed across 28 EU countries. Key findings from the ECHA report include:

• 95% of SDSs (2412 out of 2528) were proactively provided to recipients,

• 87% (2095 out of 2412) used the correct format required as of January 1, 2023,

• 81% of companies had systems in place to deliver updated SDSs within the past 12 months.

These figures reflect growing awareness of the legal obligations and the importance of providing compliant and updated documentation throughout the supply chain.

SDS non-compliance – where are the critical issues?

The inspection was conducted in two phases: the first assessed document completeness, the second examined the accuracy and legal compliance of the SDS content. The overall non-compliance rate reached 35%, meaning only 65% of the inspected SDSs were fully compliant with REACH and CLP requirements.

The most frequent deficiencies were found in the following sections:

• 🔸 Section 2 – Classification and labelling – incorrect in 24% of SDSs,

• 🔸 Section 3 – Composition of the product – non-compliant in 47%,

• 🔸 Section 8 – Exposure controls and PPE – issues found in 49%.

These numbers highlight a significant risk: merely having an SDS is not enough — it must also be technically correct, complete, and legally valid.

Why professional SDS preparation matters

The high error rate suggests that:

✔️ SDS preparation requires expertise, regulatory knowledge, and industry experience,

✔️ Inaccurate SDSs may result in regulatory penalties, misclassification, or supply chain disruptions,

✔️ A well-prepared SDS is essential for safe use, proper labelling, and transport of chemicals.

What does this mean for your business?

🔎 If your SDSs have not been updated to comply with 2023 requirements, they may no longer be valid.

🔎 Updates are needed even when the composition hasn't changed.

🔎 Frequent errors in Sections 2, 3, and 8 indicate that the person preparing the SDS might lack the necessary qualifications.

Need support with safety data sheet preparation?

At SDS Create, we help companies with:

• preparation and updates of safety data sheets in compliance with REACH and CLP,

• auditing SDSs for completeness and compliance,

• implementing internal processes for SDS version control and distribution,

• tailored regulatory training for EHS and procurement teams.

📩 Contact us: info@sds-create.com

🔗 Full REF-11 project report available here: ECHA – Project Report REF-11 (PDF)

info@sds-create.com

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