SDS regulatory calendar 2026-2028: dates that change your safety data sheet

The calendar at a glance

Status as of 5 November 2026. Dates are taken from the text of each regulation on EUR-Lex; see the sources at the end.

New hazard classes: ED, PBT/vPvB, PMT/vPvM

Delegated Regulation (EU) 2023/707 added hazard classes to CLP for endocrine disruption (human health and environment), for persistent, bioaccumulative and toxic substances (PBT, vPvB) and for persistent, mobile and toxic substances (PMT, vPvM). The classes come with new supplemental hazard statements: EUH380 and EUH381 (endocrine disruption, human health), EUH430 and EUH431 (endocrine disruption, environment), EUH440 and EUH441 (PBT, vPvB), EUH450 and EUH451 (PMT, vPvM). No pictogram has been assigned to the new classes; the regulation notes that one will follow if the UN GHS adopts it.

• Substances: classified under the new criteria from 1 May 2025. A substance placed on the market before that date had until 1 November 2026.
• Mixtures: classified from 1 May 2026. A mixture placed on the market before that date has until 1 May 2028.
• Mixture thresholds: a mixture is classified for endocrine disruption when a component is present at 0.1 % or more (Category 1) or 1 % or more (Category 2); for PBT/vPvB the component limit is 0.1 % by weight.
• SDS on request: for a mixture that is not classified but contains an endocrine-disruption Category 2 component at 0.1 % or more, an SDS must be available on request.

In practice this changes Section 2 (classification and label elements), Section 3 (composition) and the toxicological and ecological information in Sections 11 and 12. See how the mixture calculation works in CLP mixture classification.

Annex VI updates

Each update of the harmonised classification list (CLP Annex VI, Part 3) changes the classification a supplier must use for the listed substances. When the classification of a substance in your product changes, Sections 2 and 3 of your SDS and the label have to follow. REACH Article 31(9) requires a supplier to update the SDS without delay when new hazard information becomes available. The three updates in this period apply on 1 September 2025 (Regulation (EU) 2024/197), 1 May 2026 (Regulation (EU) 2024/2564) and 1 February 2027 (Regulation (EU) 2025/1222). The regulation for May 2026 allows early voluntary application, so a supplier you buy from may already have switched.

REACH Annex II: what the 2020/878 format added

• Section 1.1: the UFI, when the mixture has one and it is given in the SDS.
• Nanoforms: the regulation was adopted partly to carry nanoform information into the SDS.
• Section 11.2.1 and Section 12.6: information on endocrine-disrupting properties, for health and for the environment.
• Section 3: specific concentration limits, M-factors and acute toxicity estimates for substances listed in CLP Annex VI.
• Section 9: 9.1 basic physical and chemical properties and a new 9.2 for other information.

The transition ended on 31 December 2022, so an SDS in the pre-2021 format no longer meets the rules. We found no newer amendment of Annex II that adapts the SDS to the 2023/707 classes; check the consolidated text of REACH for any later change. The section-by-section content is in the 16 sections of an SDS explained.

CLP revision (Regulation (EU) 2024/2865)

The CLP revision applies in groups, from 1 July 2026 and from 1 January 2027. In the text we reviewed, the term "safety data sheet" appears only in a provision on copies for the armed forces, so the revision does not change the SDS format, which stays in REACH Annex II. Its impact is on labelling: a minimum character size table (for example 1.2 mm for packages of up to 0.5 litre), digital labels and rules for refill stations. We did not match every provision to its exact date, so check the regulation for your products. For label questions see chemical label requirements.

Poison centre notification and UFI

CLP Annex VIII requires a harmonised notification to poison centres and a unique formula identifier (UFI) for mixtures classified for health or physical hazards. Industrial-use mixtures have had to comply since 1 January 2024; mixtures that were already notified under national systems had until 1 January 2025. The details are in UFI code and poison centre notification.

A short check for your own SDSs

1. Is the SDS in the 2020/878 format (UFI in 1.1, 11.2.1 and 12.6, Section 9.2)?
2. Do your substances have a new harmonised classification since 1 September 2025? Compare Sections 2 and 3 with the current Annex VI.
3. Is any substance in your mixture endocrine-disrupting, PBT/vPvB or PMT/vPvM? Check the thresholds above; for substances the deadline already passed on 1 November 2026.
4. Does the label match Section 2, including supplemental statements such as EUH380 to EUH451?
5. Is the UFI on the label and notified to the poison centres where required?

The SDS checker reviews a file for missing sections and inconsistencies between Sections 2, 3 and 14. It is a first check, not a compliance certificate.

This article summarises legal texts for orientation only; it is not legal advice. Dates come from the regulations as published on EUR-Lex. Check the current consolidated texts before relying on them.

Sources

• Commission Delegated Regulation (EU) 2023/707, new CLP hazard classes — CELEX:32023R0707.
• Commission Delegated Regulation (EU) 2024/197 — CELEX:32024R0197.
• Commission Delegated Regulation (EU) 2024/2564 — CELEX:32024R2564.
• Commission Delegated Regulation (EU) 2025/1222 — CELEX:32025R1222.
• Commission Regulation (EU) 2020/878, REACH Annex II — CELEX:32020R0878.
• Commission Delegated Regulation (EU) 2020/1677, CLP Annex VIII — CELEX:32020R1677.
• Regulation (EU) 2024/2865, CLP revision — CELEX:32024R2865.
• REACH, Regulation (EC) No 1907/2006, Article 31 — CELEX:02006R1907.