Contents
In short: No SDS has a fixed expiry date. In the EU and Great Britain, REACH Article 31(9) requires an update without delay on three triggers, and the revised sheet goes to every customer supplied in the preceding 12 months. In the US, OSHA's 29 CFR 1910.1200(g)(5) allows three months to add significant new hazard information, and the updated sheet travels with the next shipment. Regulatory changes such as CLP adaptations, new harmonised classifications and Candidate List additions are the triggers suppliers miss most often.
The legal triggers side by side
| Point | EU (REACH) | Great Britain (UK REACH) | United States (OSHA HazCom) |
|---|---|---|---|
| Trigger | New information that may affect risk management measures or new hazard information; authorisation granted or refused; restriction imposed (Art. 31(9)) | Same three triggers (Art. 31(9), GB text) | New information on the hazards or on ways to protect against them that is significant (paragraph (g)(5)) |
| Deadline | Without delay | Without delay | Within three months of becoming aware |
| Who receives it | All recipients supplied within the preceding 12 months | All recipients supplied within the preceding 12 months | Distributors and employers, with the first shipment after the update (paragraph (g)(6)(i)) |
| Marking | "Revision: (date)" on page 1, the version replaced, and the changes indicated, normally in Section 16 (Annex II, 0.2.5) | "Revision: (date)" (Art. 31(9)); GB Annex II has its own wording | Date of preparation or last revision in Section 16 (Appendix D) |
| Product no longer made | No exemption for past recipients | No exemption for past recipients | Information added before the chemical is introduced into the workplace again |
EU and GB: Article 31(9) in practice
The text is short: suppliers "shall update the safety data sheet without delay" on the three occasions, and the new, dated version, identified as "Revision: (date)", goes free of charge, on paper or electronically, "to all former recipients to whom they have supplied the substance or mixture within the preceding 12 months". Any update following registration must include the registration number. The same paragraph appears in the GB text of UK REACH.
Three points cause most of the trouble:
- "Without delay" is not a grace period. Unlike the US rule, there is no fixed number of months. Plan the update as soon as the trigger is known, even if the legal change applies later, so the revised sheet is ready on the application date.
- The 12-month list. You need a sales record that tells you who bought each product in the last 12 months. Sending the new sheet only with future deliveries does not satisfy Article 31(9).
- Showing what changed. Annex II, section 0.2.5, as replaced by Regulation (EU) 2020/878, requires the changes to be brought to the recipients' attention in Section 16 unless indicated elsewhere. A line such as "Section 2: classification updated following Delegated Regulation (EU) 2024/2564; Section 8: new EU limit value" is enough; a bare revision number is not.
Not every edit is a legal trigger. A corrected phone number or a typo fix may be issued as a new version, but the 12-month redistribution duty attaches to the three triggers. When in doubt, treat a change to classification, composition, exposure controls or first aid as a trigger.
United States: the three-month rule
Paragraph (g)(5) of 29 CFR 1910.1200 requires the SDS preparer to ensure that the information "accurately reflects the scientific evidence". When the manufacturer, importer or employer preparing the sheet becomes newly aware of significant information on the hazards or on protective measures, it must be added within three months. If the chemical is not currently produced or imported, the information must be added before the chemical is introduced into the workplace again. Paragraph (g)(6)(i) requires an appropriate SDS with the initial shipment and with the first shipment after the SDS is updated. There is no 12-month look-back distribution as in Europe.
The 2024 revision of the standard (89 FR 44144, 20 May 2024) is itself an update trigger. OSHA extended its compliance dates by four months in a final rule published on 15 January 2026 (91 FR 1695). Paragraph (j) now reads:
- substances: manufacturers, importers and distributors by 19 May 2026; employers by 20 November 2026;
- mixtures: manufacturers, importers and distributors by 19 November 2027; employers by 19 May 2028.
Until those dates, either the revised standard or the version in force on 1 July 2023 may be followed. For the classification differences behind these updates, see CLP vs GHS vs OSHA HazCom.
Regulatory triggers to watch
Most SDS revisions are not caused by new test data but by changes in the law. The following are the recurring ones in the EU:
- Adaptations to technical progress (ATPs) of CLP. Each ATP amends the harmonised classification list in Annex VI and sets its own application date. For example, Commission Delegated Regulation (EU) 2024/2564, which amends harmonised classifications, applies from 1 May 2026, with voluntary early application allowed from its entry into force. If a component's entry changes, the mixture classification in Section 2 and the component data in Section 3 may change too.
- New hazard classes. Delegated Regulation (EU) 2023/707 added endocrine disruption and PBT/vPvB, PMT/vPvM classes. Substances must be classified under them from 1 May 2025 (1 November 2026 for substances already on the market before that date), and mixtures from 1 May 2026 (1 May 2028 for mixtures already on the market before then).
- Candidate List additions. A new SVHC triggers Section 3 and Section 15 changes for substances, and can create an SDS-on-request duty for non-classified mixtures at 0.1 % (REACH Art. 31(3)(b)). See REACH Article 31 obligations.
- Authorisations and restrictions. A decision on an Annex XIV substance or a new Annex XVII entry is an explicit trigger under Art. 31(9)(b) and (c).
- Occupational exposure limits. New or revised EU limit values, and national limits in each market, change Section 8.
- Supplier SDS revisions. When a raw material SDS changes, the information may affect your mixture. REACH Article 34 also requires you to pass new hazard information upstream.
Great Britain does not follow EU ATPs automatically. GB has its own mandatory classification list, and its Annex II was not replaced by 2020/878, so an EU-driven revision does not always need a GB revision, and the reverse also holds. Track the two markets separately; the comparison of EU, UK and US SDS requirements sets out the structural differences.
A simple update routine
- Keep a register of products, the components behind them and their CAS numbers.
- Review regulatory changes against the register at fixed intervals, for example each quarter, and immediately when a supplier SDS changes.
- For each trigger, decide which sections change and record the reason; that note becomes the Section 16 change log.
- Issue the revision with "Revision: (date)" and the replaced version, then send it to the 12-month customer list (EU, GB) or attach it to the next shipment (US).
- Check the label against the new classification. The free label tool helps with the CLP label elements.
Chemoris recalculates the classification from component data whenever you regenerate an SDS, which makes a regulatory update a matter of reviewing the changes rather than rewriting the sheet. Open a free account to see how a revision looks. For the Turkish KKDİK rules on the same question, see when to update a Turkish SDS.
Frequently asked questions
Do I have to update an SDS every few years?
No. Neither REACH, UK REACH nor OSHA sets a fixed review cycle. They require updates when a trigger occurs. A periodic internal review is good practice to make sure no trigger was missed.
Who must receive a revised SDS in the EU?
Every recipient to whom you supplied the substance or mixture within the preceding 12 months, free of charge, on paper or electronically (REACH Art. 31(9)).
How long do I have in the US?
Three months from becoming aware of significant new information (29 CFR 1910.1200(g)(5)). The updated SDS must go with the first shipment after the update.
This article summarises legal texts for orientation only; it is not legal advice. Check the current consolidated texts and compliance dates before relying on it.
Sources
- REACH, Regulation (EC) No 1907/2006, Articles 31 and 34 and Annex II (consolidated text) — CELEX:02006R1907.
- UK REACH Article 31 (GB text) — legislation.gov.uk.
- 29 CFR 1910.1200, paragraphs (g)(5), (g)(6) and (j) — ecfr.gov.
- OSHA, Hazard Communication Standard, compliance date extension, 91 FR 1695, 15 January 2026 — federalregister.gov.
- Commission Delegated Regulation (EU) 2023/707 (new hazard classes) — CELEX:32023R0707.
- Commission Delegated Regulation (EU) 2024/2564 (harmonised classifications, Annex VI to CLP) — CELEX:32024R2564.
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