UK REACH and GB CLP set the framework for SDS duties in the United Kingdom, with COSHH turning those duties into day-to-day controls. This guide explains when an SDS is required under GB REACH and CLP, and how those duties support COSHH obligations.
It clarifies the roles across the supply chain, the point at which documentation becomes necessary, and how exposure scenarios relate to extended SDS. Update expectations and good access practices are discussed.
When is an SDS required
An SDS is required when a substance or mixture is classified as hazardous under GB CLP. Content and format follow UK REACH Annex II. The table below expands upon the requirements further:
| Scenario | Brief | Thresholds/conditions | What to do |
|---|---|---|---|
| Hazardous substance or mixture | SDS support safe professional and industrial use. | Classified as hazardous under CLP and supplied to professional/industrial recipients. | Provide an SDS at or before first supply, in English and Annex II format. |
| PBT/vPvB or SVHC substance | Certain substances call for an SDS even if not classified. | Substance is PBT/vPvB or on the Candidate List. | Provide an SDS at or before first supply. |
| Mixture not classified — on request | Some mixtures merit an SDS on request. | Listed component hazards at set thresholds (including WEL situations). | Provide an SDS upon request from a downstream user or distributor. |
| Extended SDS (eSDS) | Exposure scenarios travel with the SDS when required. | A chemical safety report is required and the substance is hazardous. | Attach exposure scenarios and pass them on unchanged. |
| Updated SDS | New information should reach recent customers. | New hazard data or risk-management advice; authorisation/restriction decisions. | Update without delay and send the revision to all recipients from the previous 12 months. |
| General public sales | Labels and basic information can be sufficient. | Supplied to the general public with information adequate for safe use. | No SDS needed, unless a downstream user or distributor requests one. |
UK Requirements for provision, format, and delivery
UK REACH and GB CLP provides guidelines for provision, format, and workflow regarding SDSs. This compact checklist lists the requirements below:
| Requirement / Step | What applies | Quick check |
|---|---|---|
| Timing (first supply) | Provide the SDS before or at first delivery; not only by posting it on a website. | Was the SDS sent with or ahead of first supply? |
| How to deliver | Both paper or electronic formats are accepted. A generic web link alone is not enough; actual delivery is required. | Was the SDS directly delivered or a direct link agreed? |
| Language | Supply the SDS in English. | Is the English version available for the recipient? |
| Structure (Annex II) | Use the 16-section SDS. Follow Annex II content and formatting rules. | Are all sections present, clear, and dated? |
| Emergency number | Include an emergency phone number in Section 1.4 with competent responders. | Does Section 1.4 list a working number? |
| Exposure scenarios | If a CSR is required, annex exposure scenarios for identified uses. | Are exposure scenarios attached where needed? |
| Updates | Update without delay when new hazard or RMM info arises, or after an authorisation or restriction decision. | Have you issued a revised, dated SDS and flagged changes? |
| Resend on update | Send the updated SDS to all recipients from the preceding 12 months. | Have last-12-month recipients received the revision? |
| Record-keeping | Keep information needed to meet duties for 10 years. | Are SDS and change records stored and retrievable? |
Obligations after initial supply
Under REACH Article 31, SDS are updated without delay when new hazard or risk-management information emerges, or when authorisation/restriction decisions change obligations.
Updated SDS are provided to all recipients supplied in the previous 12 months, with the revision date and changes signposted. Where exposure scenarios apply, the annex is forwarded intact and reflected in the COSHH assessment.
Ensure access in the company
SDS are a key input to your COSHH risk assessment and to information, instruction, and training. Make them easy to reach for supervisors and crews. SDS help you select controls, PPE, storage, and emergency steps. Keep them current and ensure workers know where to find them and how to use them in practice.
Key takeaway to stay compliant
Consistency comes from timely SDS updates, clear Annex II formatting, forwarding exposure scenarios where required, and keeping access straightforward for workers, supported by records that show what changed and when.
Frequently asked questions (FAQ)
1. Do I have to send a new SDS with every order?
No. Provide an SDS at or before first supply. Send an updated SDS when you revise it, and resend to recipients from the previous 12 months.
2. Is a link on my website enough?
No, not by itself. You must deliver the SDS on paper or electronically. A generic web link alone is not sufficient. A direct link may be acceptable if agreed with the customer.
3. When is an SDS required for products sold to the public?
If sold to the general public, an SDS is not needed when the label and other information are enough for safe use. Downstream users or distributors can still request an SDS.
4. What format must the SDS follow?
Use the 16-section layout in Annex II. Keep clear language, date of compilation on page one, and highlight changes on revision.
5. How do SDS link to our workplace controls?
Use SDS content to build the COSHH assessment and training. SDS are essential inputs but are not a risk assessment on their own.