SDS Requirements for International Shipping

1. What Is a Safety Data Sheet?

A Safety Data Sheet (SDS) is a standardized document that communicates hazard information about chemical substances and mixtures. It is the primary tool for transmitting safety, handling, and regulatory information through the supply chain — from manufacturer to importer to downstream user.

The SDS replaced the older Material Safety Data Sheet (MSDS) as part of the global adoption of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Under GHS, every SDS follows a standardized 16-section format that is recognized worldwide. This harmonization means that an SDS prepared in the United States follows the same structural format as one prepared in Germany, Japan, or Brazil.

What Information Does an SDS Provide?

The 16 sections of an SDS cover every aspect of safe handling, transportation, and emergency response for a chemical product:

• Product identification and supplier contact details
• Hazard classification and label elements (pictograms, signal words, H/P statements)
• Chemical composition and ingredient information
• First-aid measures and firefighting procedures
• Handling, storage, and exposure control guidance
• Physical and chemical properties (flash point, pH, density, etc.)
• Stability, reactivity, and toxicological data
• Ecological information and disposal considerations
• Transport information — including the UN number, proper shipping name, hazard class, and packing group needed for shipping documentation
• Regulatory status under applicable national laws

The SDS is not a consumer-facing document. It is designed for professionals in workplaces, laboratories, warehouses, and logistics operations who handle, store, or transport chemical products.

2. SDS vs MSDS — What Changed?

The MSDS (Material Safety Data Sheet) was the pre-GHS format used primarily in the United States and a few other countries. It served the same general purpose as the SDS — communicating chemical hazard information — but lacked a standardized structure. Different countries and even different manufacturers used varying formats, section orders, and hazard classification systems.

Key Differences Between MSDS and SDS

The transition from MSDS to SDS was completed years ago. In the US, OSHA's Hazard Communication Standard required all chemical manufacturers and importers to switch to the GHS-aligned SDS format by June 1, 2015. If a supplier still provides a document labeled "MSDS," it is outdated — request an updated SDS immediately. An MSDS does not meet current regulatory requirements under OSHA, REACH, or WHMIS.

3. When Do You Need an SDS?

The SDS requirement is tied to the supply chain, not to the end consumer. Understanding when an SDS is required — and when it is not — prevents both compliance gaps and unnecessary overhead.

Additional EU SDS Triggers

Under REACH Article 31(1)(b), an SDS must also be provided for substances identified as persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB), regardless of whether they are classified as hazardous under CLP. Additionally, under REACH Article 31(3), a downstream user or distributor can request an SDS for non-classified mixtures if they contain certain substances above specified thresholds (e.g., substances with EU workplace exposure limits, or SVHC candidates at >= 0.1%).

The Key Principle

The SDS accompanies the supply chain, not the consumer. A B2B buyer purchasing 50 kg of fragrance oil must receive an SDS. A consumer buying a single finished candle from your Etsy shop does not need one in the box — though you should have the SDS for your raw materials on file and be able to provide it on request.

Even when an SDS is not legally required to accompany a shipment, having one available is strongly recommended for any product containing classified substances. Customs authorities in the EU, US, and Canada may request an SDS during inspection of commercial shipments, and failing to produce one can result in delays or holds.

4. The 16 Sections of an SDS

The GHS specifies a fixed 16-section structure. Every SDS worldwide follows this order. The content within each section may vary by jurisdiction, but the section numbering and titles are universal.

Sections 12–15: A Jurisdictional Note

In the EU, all 16 sections are mandatory under REACH Annex II. In the United States, OSHA enforces Sections 1–11 and 16 under 29 CFR 1910.1200. Sections 12–15 are considered "non-mandatory" by OSHA because they fall under the jurisdiction of other agencies (EPA for ecological/disposal, DOT for transport, etc.). However, Sections 12–15 must still be present in the SDS even in the US — they simply are not enforced by OSHA. Omitting them would render the SDS non-compliant with GHS and unusable for international trade.

5. US SDS Format (OSHA HazCom 2012/2024)

In the United States, SDS requirements are governed by OSHA's Hazard Communication Standard, 29 CFR 1910.1200. This regulation requires chemical manufacturers, importers, and distributors to provide an SDS for every hazardous chemical they produce or import.

Key US Requirements

• The SDS must follow the GHS 16-section format as specified in Appendix D of 29 CFR 1910.1200
• OSHA directly enforces Sections 1 through 11 and Section 16
• Sections 12 through 15 fall under the jurisdiction of DOT (transport) and EPA (environment/disposal) but must still appear in the SDS
• The SDS must be in English for the US market
• Employers must maintain SDSs for all hazardous chemicals in the workplace and ensure they are readily accessible to employees during their work shift

The 2024 HazCom Update

OSHA published a final rule in 2024 updating the Hazard Communication Standard to align more closely with GHS Revision 7. Key changes include updated classification criteria for certain health and physical hazards, new hazard categories, and revised label element requirements. Chemical manufacturers and importers must comply with the updated classification and SDS requirements according to the phased compliance schedule, with full compliance required by 2028.

For small businesses handling finished consumer products (candles, cosmetics, soap), the practical impact is that your raw material suppliers should be providing updated SDSs that reflect the 2024 HazCom changes. If you receive a new SDS from a supplier, replace the old version in your files immediately.

6. EU SDS Format (REACH Annex II)

In the European Union, SDS requirements are established under REACH Regulation (EC) No 1907/2006, Article 31. The format and content are specified in Commission Regulation (EU) 2020/878, which updated REACH Annex II to align with GHS and CLP classification.

Key EU Requirements

• All 16 sections are mandatory — no sections are designated as non-mandatory
• The SDS must be provided in the official language(s) of each EU member state where the product is placed on the market
• For substances registered above 10 tonnes/year under REACH, exposure scenarios may be annexed to the SDS (known as an "extended SDS" or eSDS)
• A UFI (Unique Formula Identifier) code must be included in Section 1.1 for mixtures that require Poison Centre Notification under CLP Annex VIII
• The SDS must include the REACH registration number for registered substances

Language Requirements

The EU language requirement is one of the most significant practical differences for international sellers. An SDS provided in English alone is not sufficient if the product is supplied to France (French required), Germany (German required), or Spain (Spanish required). Each member state has its own official language(s), and the SDS must be available in all applicable languages. For sellers entering multiple EU markets, this means maintaining translated versions of every SDS.

UFI Code in the SDS

Since January 1, 2021 (for consumer and professional use mixtures), any mixture classified as hazardous and placed on the EU market must have a UFI code on both the product label and in Section 1.1 of the SDS. The UFI links the product to the Poison Centre Notification submitted via the ECHA PCN portal, enabling emergency responders to quickly identify the exact formulation in case of poisoning incidents.

7. Canada SDS Format (WHMIS 2015)

Canada's SDS requirements fall under the Workplace Hazardous Materials Information System (WHMIS 2015), which aligned Canadian hazard communication with GHS. The legal framework is the Hazardous Products Act (HPA) and the Hazardous Products Regulations (SOR/2015-17).

Key Canadian Requirements

• Must follow the GHS 16-section format
• Bilingual requirement: SDSs must be available in both English and French
• SDSs must be updated at least every 3 years, or sooner when significant new information becomes available (e.g., new toxicological data, reclassification of hazards)
• Canadian-specific OELs (Occupational Exposure Limits) must be included in Section 8 where applicable
• The SDS must reference Canadian regulatory statuses, including DSL/NDSL (Domestic Substances List / Non-Domestic Substances List) in Section 15

US vs EU vs Canada — Quick Comparison

8. Who Creates the SDS?

The responsibility for creating an SDS falls on the manufacturer or importer of the chemical substance or mixture. In the supply chain, this means the entity that first places the product on the market in a given jurisdiction.

Responsibility by Role

• Chemical manufacturer: Creates the original SDS for the substance or mixture they produce
• Importer: If importing a substance into a new jurisdiction (e.g., importing into the EU), the importer is responsible for ensuring an SDS exists in the required format and language(s)
• Downstream formulator / blender: If you combine ingredients to create a new mixture (e.g., blending fragrance oils into a base), you are the manufacturer of that new mixture and are responsible for its SDS
• Distributor / reseller: Not required to create the SDS but must pass it along to B2B customers

For Small Sellers Buying Finished Blends

If you purchase ready-made fragrance oils, wax blends, or cleaning concentrates from a supplier, that supplier is responsible for providing the SDS. You should receive an SDS for every raw material and blend you purchase. Keep these on file — they are required for your own workplace safety records and are essential documentation if customs ever questions a shipment.

You are not required to create an SDS for a finished consumer product (such as a poured candle or a bar of soap) if it is sold only to consumers. However, you should have SDSs on file for all raw materials and fragrance components used in production. If a B2B customer or customs authority requests an SDS for your finished product, you should be able to provide one or direct them to the relevant raw material SDSs.

When You Must Create an SDS

If you reformulate, blend, or mix ingredients to create a new mixture, you are the manufacturer of that mixture and are responsible for its SDS. This applies even if each individual ingredient already has its own SDS. The resulting mixture is a new product and requires its own classification and SDS. Many SDS authoring services and software tools are available to assist with this process, typically costing between $100 and $500 per SDS depending on complexity.

9. SDS and International Shipping

When shipping chemical products internationally, the SDS plays a central role in both regulatory compliance and practical logistics. While the SDS itself is not a transport document, it contains the critical information needed to complete shipping documentation correctly.

When Customs May Request an SDS

• Commercial shipments of classified (hazardous) mixtures crossing international borders
• Bulk or wholesale quantities of chemical products
• Any shipment flagged for inspection — customs officers may request an SDS to verify hazard classification
• Shipments where the product description on the commercial invoice suggests chemical content (e.g., "fragrance oil," "essential oil," "cleaning concentrate")
• Shipments to or through countries with strict chemical import regulations (EU, South Korea, Turkey, etc.)

What to Include in Shipping Documentation

For any international shipment of a classified mixture, best practice is to include the following documentation:

• Commercial invoice — product description, HS code, declared value, origin
• Packing list — quantities, weights, package count
• SDS — recommended for any classified mixture; required if the product is classified as dangerous goods
• Dangerous goods declaration — required if the product meets dangerous goods classification thresholds (separate from the SDS)

Using SDS Section 14 for Transport

Section 14 of the SDS — Transport Information — is the single most important section for shipping compliance. It provides:

• UN number: The four-digit identifier assigned to dangerous goods (e.g., UN 1266 for perfumery products)
• Proper shipping name: The standardized name used on transport documents (e.g., "PERFUMERY PRODUCTS")
• Hazard class: The transport hazard class (e.g., Class 3 for flammable liquids)
• Packing group: Indicates the degree of danger (I = great, II = medium, III = minor)
• Environmental hazards: Whether the product is a marine pollutant or environmentally hazardous substance

This information feeds directly into the dangerous goods declaration, carrier booking forms, and customs documentation. Without it, carriers and customs brokers cannot properly classify and handle the shipment.

10. Compliance Checklist

SDS Management

• Obtain a current GHS-format SDS for every raw material, fragrance oil, and chemical blend you purchase
• Verify that each SDS follows the 16-section GHS format — reject any document still labeled "MSDS"
• Store all SDSs in an organized, readily accessible location (digital or physical) for employee access
• Replace SDSs when suppliers provide updated versions — do not retain outdated versions as the primary copy
• If you blend or reformulate ingredients, create an SDS for each resulting mixture
• Review SDSs at least annually to ensure none are outdated or missing

When Shipping Internationally

• Include the SDS with shipping documentation for all commercial shipments of classified mixtures
• Verify that Section 14 (Transport Information) of the SDS contains the UN number, proper shipping name, hazard class, and packing group
• For EU-bound shipments, ensure the SDS is in the REACH Annex II format and translated into the destination country's official language(s)
• For Canada-bound shipments, ensure the SDS is available in both English and French
• Confirm that any classified mixture shipped to the EU includes a UFI code in Section 1.1 of the SDS and on the product label
• Keep copies of all SDSs included with shipments for your records
• If customs requests an SDS and you do not have one, contact your supplier immediately — do not ship without documentation for classified products

11. Common Mistakes

These are the SDS-related errors that most frequently cause shipping delays, customs holds, and compliance gaps for small businesses.

Using an Outdated MSDS Instead of a Current SDS

If the document is labeled "MSDS" or lacks the standardized 16-section format, it does not meet current requirements under OSHA HazCom, REACH, or WHMIS. An MSDS may be rejected by customs, B2B customers, and regulatory inspectors. Request an updated GHS-format SDS from your supplier immediately.

Providing a US-Format SDS for EU Shipments

A US-format SDS (compliant with 29 CFR 1910.1200) is not automatically compliant with REACH Annex II. EU SDSs must include the UFI code, REACH registration numbers, EU-specific OELs, and may require annexed exposure scenarios. The SDS must also be in the official language of the destination member state. Sending an English-only, US-format SDS with an EU shipment can result in holds or rejection at customs.

Not Having SDSs for Raw Materials

Even if you sell only finished consumer products, you are expected to have SDSs for all hazardous raw materials in your workplace. This is an OSHA requirement for employee safety, and it is the foundation for responding to customs inquiries, customer requests, or emergency situations.

Assuming Consumer Products Never Need an SDS

While finished consumer products generally do not require an SDS to accompany the sale, customs authorities can and do request SDSs for commercial shipments — even for finished goods. If you are shipping internationally and your product contains classified substances, having an SDS available is a practical necessity, not just a legal one.

Not Translating the SDS for EU Member State Languages

An SDS provided only in English is insufficient for most EU member states. France requires French, Germany requires German, Italy requires Italian, and so on. Failure to provide a translated SDS can result in market access denial and supply chain disruption. Budget for professional SDS translation when entering new EU markets.

Not Updating the SDS When Formulations Change

Any change in a product's formulation — new fragrance blend, different supplier for a key ingredient, adjusted concentration — may alter the hazard classification and require a revised SDS. Using an SDS that no longer reflects the actual product composition is a compliance violation and a safety risk. Update the SDS whenever the formulation changes and distribute the revised version to all downstream recipients.