Regulations for Safety Data Sheets

Updated April 2025.

Safety data sheets (SDS’s) provide critical information on chemicals, describing the hazards they present, and give information on handling, storage and emergency measures in case an accident or incident occurs.

There are several pieces of legislation that govern SDS’s, both on a national and international level. In this blog, we will take a look at some of these key regulations:

International 

Globally Harmonised System (GHS)

As an answer to the extremely fragmented international landscape for SDS, the UN proposed the ‘Globally Harmonized System of Classification and Labelling of Chemicals’ in 2002. This system is intended to harmonise hazard communication and ensure that information on physical hazards and toxicity is readily available. Another benefit is the facilitating of international trade.

The GHS has been adopted by most major countries including the EU, UK, USA, Canada, China and Japan.  

The three main components of GHS are: 

• Hazard classification 
• Chemical labelling 
• The use of standardised safety data sheets 

The GHS is currently on its 10^th revision and is expected to be updated in 2025. 

If you want to learn more about the GHS in detail, take a look at our blog. 

European Union 

Regulation on classification, labelling and packaging of chemicals (CLP) 

In the EU, the classification, labelling and packaging requirements of the GHS were transposed into law in the form of the CLP regulation. Note that there are some differences between the two, as the CLP also incorporates older EU law. 

All hazardous chemicals (substances and mixtures) placed on the market must be classified, labelled and packaged according to the CLP Regulation (EC) No. 1272/2008 since 1st June 2015. 

The revised CLP regulation entered into force in December 2024. 

The CLP regulation has been implemented by EU constituent states at a national level, for example the Chemicals Act 2008 in Ireland. 

REACH Regulation 

REACH refers to ‘Regulation No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals’. It is how the SDS format and content requirements of the GHS are regulated in the EU.

Under REACH, an SDS is legally required for any hazardous chemical products.  

REACH targets manufacturers and/or those importing hazardous chemicals into the European market, but any supplier of a substance or mixture must provide an SDS. 

The European Chemicals Agency (ECHA) is responsible for managing REACH. 

Note that REACH applies in Norway through the EEA Agreement. 

United Kingdom 

GB CLP 

After the UK withdrew from the European Union in 2018 (‘Brexit’), the EU CLP regulation was retained in Great Britain as ‘GB CLP’. Under GB CLP, the main duties to classify, label and package substances remain, but will be updated and amended independently of EU CLP. 

The Health and Safety Executive (HSE) is the agency responsible for overseeing GB CLP. 

Note that in Northern Ireland EU CLP applies. 

UK REACH  

Post Brexit, the EU REACH regulation was brought into UK law as ‘UK REACH’ in 2021. 

SDS are a requirement under the UK REACH legislation. 

The Department for Environment Food and Rural Affairs (DEFRA) is the body responsible for managing UK REACH. 

Note that Northern Ireland EU REACH still applies. 

United States of America

Hazard Communication Standard/ HCS  

In the USA, the Hazard Communication Standard (HCS) requires that the identities and hazards of chemicals be made available and understandable to workers. 

The HCS has aligned with the GHS since 2012 and requires that the chemical manufacturer, distributor, or importer of hazardous chemicals provide a SDS with each substance. 

The HCS is managed by the Occupational Health and Safety Administration (OSHA). 

Canada 

Workplace Hazardous Materials Information System (WHMIS) 

In Canada, the Workplace Hazardous Materials Information System (WHMIS) provides information on hazardous products that may be used, handled or stored in Canadian workplaces.  

WHMIS has aligned with the GHS since 2015. Every product classified as ‘hazardous product’ under WHMIS requires an SDS.  

WHMIS is managed by the Canadian Centre for Occupational Health and Safety (CCOHS). 

Note that SDSs in Canada must be available in both English and French. 

Chemical Classification 

It is not enough to have an SDS, you must have the relevant safety data sheet compliant for your geographical region. 

A compliant SDS should have the following in the EU/EEA, UK, USA and Canada. 

• Sixteen sections 
• Classified and labelled under GHS/CLP 
• In the language of the market where the product is being positioned 

How to effectively manage SDS

There is a lot more to safety data sheets than is contained within this blog. Organisations need to:

• familiarise themselves with the GHS/CLP and local regulations to ensure their SDS and labelling practices comply, 
• make sure that their workers know how to read an SDS
• have an effective management strategy for hundreds, potentially thousands of documents (which must be accessible to workers) 

Fear not, there is help available! Our team source the SDS for your region, allowing your team to ascertain the correct regional SDS information to ensure you are compliant. Our SDS Management Solution stores all your documentation so staff members can access relevant chemical information when required. 

At Chemical Manager we are building a database of the regulations listed on your SDS, so you can see at a quick glance if you have a compliant safety data sheet for your region. 

Take a closer look at our SDS management software by clicking the banner below: