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Regulation

SDS requirements compared: EU REACH, UK REACH and US OSHA HazCom

EU REACH Annex II (2020/878), UK REACH and OSHA HazCom 1910.1200 compared: who supplies the SDS, language, format and update deadlines.

Updated: 8 min read

Contents
  1. Why one SDS is not enough
  2. Comparison table
  3. European Union: REACH Article 31 and Annex II
  4. Great Britain: UK REACH and GB CLP
  5. United States: OSHA HazCom (29 CFR 1910.1200)
  6. Practical approach for one product in three markets
  7. Frequently asked questions
  8. Sources

In short: The EU, Great Britain and the United States all use a 16-section safety data sheet, but the legal texts behind it are different. In the EU the SDS follows REACH Annex II as amended by Regulation (EU) 2020/878. In Great Britain it follows the retained UK REACH Annex II, which was not updated by 2020/878, and it must be supplied in English. In the US it follows OSHA's Hazard Communication Standard, 29 CFR 1910.1200, which also requires English and gives suppliers three months to add significant new hazard information. One document rarely fits all three markets without changes.

Why one SDS is not enough

All three systems took their SDS structure from the UN Globally Harmonized System (GHS), so the section numbers and headings line up. The differences lie in who supplies the sheet, its language, subsection content and update speed. A sheet written for the EU market will often be rejected by a US customer's EHS team because the classification uses a category OSHA does not recognise, and a sheet written in the US format will be incomplete in the EU because it lacks subsections that Annex II makes mandatory.

Comparison table

PointEUGreat Britain (England, Scotland, Wales)United States
Legal basisREACH (EC) No 1907/2006, Article 31 and Annex II, as amended by Regulation (EU) 2020/878 UK REACH (retained Regulation 1907/2006), Article 31 and Annex II OSHA Hazard Communication Standard, 29 CFR 1910.1200(g) and Appendix D
Format16 sections with numbered subsections (Annex II Part B)16 sections with numbered subsections (pre-2020/878 Annex II text) 16 sections in a specified order (paragraph (g)(2)); minimum content in Appendix D
Who suppliesThe supplier of the substance or mixture, to the recipientThe supplier, to the recipient Chemical manufacturers and importers; distributors pass it on; employers keep one for each hazardous chemical
LanguageOfficial language(s) of the Member State where the product is placed on the market (Art. 31(5)) English; other languages may be added (Art. 31(5) as amended for GB) English; employers may keep copies in other languages too (paragraph (g)(2))
When suppliedFree of charge, on paper or electronically, no later than first delivery (Art. 31(8)) Free of charge, on paper or electronically, no later than first supply (Art. 31(8)) With the initial shipment and with the first shipment after an update (paragraph (g)(6)(i))
Update trigger"Without delay" on new risk-management or hazard information, authorisation decisions or new restrictions (Art. 31(9)) Same three triggers (Art. 31(9)) New significant hazard or protection information added within three months (paragraph (g)(5))
Who gets the updateAll recipients supplied in the preceding 12 monthsAll recipients supplied in the preceding 12 months Downstream customers with the next shipment
Sections not enforcedNone; all 16 sections are mandatoryNone; all 16 sections are mandatory Sections 12 to 15 must be present, but OSHA does not enforce their content

European Union: REACH Article 31 and Annex II

Under REACH Article 31(1) the supplier must provide an SDS when a substance or mixture meets the criteria for classification as hazardous under the CLP Regulation (EC) No 1272/2008, when a substance is PBT or vPvB, or when it is on the Candidate List of substances of very high concern. Article 31(3) adds a second group: a mixture that is not classified still needs an SDS on request when it contains, for example, at least one substance posing a health or environmental hazard at 1 % or more by weight (0.2 % by volume for gaseous mixtures), or certain substances of concern at 0.1 % or more.

The content is set by Annex II. Commission Regulation (EU) 2020/878 of 18 June 2020 replaced that annex. It applies from 1 January 2021, and sheets in the older format could only be supplied until 31 December 2022, so every EU SDS in circulation today should follow the 2020/878 text. The changes it brought are the ones auditors check first:

  • UFI in subsection 1.1 where a mixture has a unique formula identifier and it is shown on the SDS (see our note on SDS for export to the EU for the poison-centre side).
  • Nanoforms: the word "nanoform" in 1.1, the particle characteristics in 3.1 and in 9.1.
  • Endocrine disrupting properties in 2.3, 11.2 and 12.6.
  • Specific concentration limits, M-factors and acute toxicity estimates for listed components in Section 3, where available.

Great Britain: UK REACH and GB CLP

After Brexit, REACH was retained in GB law as UK REACH. Article 31 keeps the same structure: an SDS for hazardous substances and mixtures, free of charge, no later than first supply, and updated without delay. Two differences matter in practice.

First, language. The GB text of Article 31(5) reads: "The safety data sheet shall be supplied in English and may also be supplied in any other language." This wording was substituted on 31 December 2020 by S.I. 2019/758.

Second, Annex II itself. The version of Annex II on legislation.gov.uk for GB is the text substituted by Regulation (EU) 2015/830; it does not contain the 2020/878 additions. Subsection 1.1, for example, asks for the product identifier "as provided on the label in English" and says nothing about a UFI. An EU 2020/878 sheet contains everything the GB annex asks for and more, but you still need to replace EU references in Section 15 with GB legislation, check that classifications follow the GB mandatory list where one exists, and give an emergency number that works in the UK.

Northern Ireland is a separate case: under the Windsor Framework, EU REACH and EU CLP continue to apply there, so a product supplied into Northern Ireland follows the EU column of the table above.

United States: OSHA HazCom (29 CFR 1910.1200)

In the US the SDS is a workplace document. Paragraph (g)(1) requires chemical manufacturers and importers to "obtain or develop a safety data sheet for each hazardous chemical they produce or import", and employers must keep an SDS for each hazardous chemical they use. Paragraph (g)(2) fixes the 16 headings and their order and requires the sheet to be in English. Paragraph (g)(6)(i) requires the SDS to go out with the initial shipment and with the first shipment after it is updated.

The US rules differ from Europe in three places that often confuse foreign suppliers:

  • Sections 12 to 15 (ecological, disposal, transport, regulatory) must be included, but OSHA states that it will not enforce their content because those topics fall under other agencies.
  • Update timing: paragraph (g)(5) gives three months to add newly learned significant information about hazards or protective measures. There is no 12-month look-back distribution as in Europe; the updated sheet goes with the next shipment.
  • Hazard classes: OSHA includes classes that CLP does not, such as combustible dust, simple asphyxiants and hazards not otherwise classified (HNOC), and it does not cover environmental hazard classes. See CLP vs GHS vs OSHA HazCom for the category-level comparison.

OSHA amended the standard by a final rule published on 20 May 2024 (89 FR 44144), effective 19 July 2024, primarily to align with GHS Revision 7. Under paragraph (j) as currently in force, manufacturers, importers and distributors must update SDSs and labels for substances by 19 May 2026 and for mixtures by 19 November 2027; until then they may comply with either the revised standard or the version in force on 1 July 2023.

Practical approach for one product in three markets

  1. Classify once per regime. CLP and HazCom both build on the GHS, but they adopted different categories, so a mixture can carry a hazard statement in the US that it does not carry in the EU, or the other way around. Our guide to classifying a mixture under CLP covers the EU side.
  2. Keep one master data set (composition, test data, physical properties) and generate three documents from it rather than editing one document three times.
  3. Localise Sections 1.4, 8 (exposure limits), 14 and 15 for each market. These are the parts that differ most; for transport see Section 14 and ADR.
  4. Track update triggers separately. An EU update must reach the last 12 months of customers; a US update rides on the next shipment.

For a section-by-section checklist that applies in all three systems, read the 16 SDS sections explained.

Frequently asked questions

Can I use my EU SDS in Great Britain?

It is a good starting point, because it contains everything the GB Annex II asks for. It must be in English and Section 15 must cite GB legislation rather than EU law; the emergency number and any GB mandatory classifications also need checking.

Does the US accept an SDS written for the EU?

Not without review. OSHA requires English and the section order in paragraph (g)(2), and the classification must follow the HazCom appendices, which include categories CLP does not use and omit environmental hazards.

This article summarises legal texts for orientation only; it is not legal advice. Check the current consolidated text of each regulation before relying on it.

Sources

Related codes

H and P statements related to this topic; each is explained in the glossary with its full wording, thresholds and label use.

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