When do you need to create a new Safety Data Sheet and when is an update enough?

In practice, it is common for the composition, classification or legal framework of products to change. With each such change, the question arises: is it enough to update the Safety Data Sheet (SDS), or is it necessary to create a new one? Distinguishing between these situations is important not only for legal compliance, but also for internal documentation management and credibility with customers.

When is it necessary to create a completely new Safety Data Sheet?

A completely new Safety Data Sheet is required when it is not just an update of information, but a completely new product.

This means:

• A mixture with different composition or a different function has been created, which significantly differs from the original mixture.
• The product is intended for a new use, or is being placed on the market under a separate commercial brand and needs to be communicated independently of the previous product.
• It is purchased abroad and placed on the market in another country.

In such cases, a revision of the existing document is not sufficient – a new SDS must be created “from scratch”.

What does an “update” of the Safety Data Sheet mean?

An update (or more precisely a revision) is a new version of the same document for the same product. It occurs when information changes but the product remains unchanged in its identity – i.e. same composition, same name, same purpose. There is no fixed time limit for updates – they must be made without undue delay once relevant circumstances are identified or in accordance with legal deadlines (e.g. related to the SDS format).

You must revise the SDS especially in the following cases:

• Change in product classification – for example, the addition of a new hazard class, adjustment of H-statements, signal word or recommended measures.
• Change in composition – for example, changes in substance concentrations or the whole formulation.
• New hazard information (either within individual substances or a revised classification calculation for the product) – obtained from scientific studies, practical experience or available data.
• Change in legal regulations – typically changes to Annex II of the REACH Regulation (SDS format and structure) or new CLP requirements.
• Changes to control parameters for Section 8.
• Administrative updates, such as updated contact details, added recommended use or clarified instructions for transport and storage.

Each update must be recorded in Section 16.

How to distinguish between the two?

A good rule of thumb is the following approach:

• Is the classification changing, but the product remains “the same”? → Update the SDS.
• Is the change so significant that a user would perceive it as a new product? → Create a new SDS.

Obligation to inform and time requirements

According to the REACH Regulation, the supplier is obliged to provide the updated SDS to customers without delay if changes:

• affect the classification of the substance or mixture,
• bring new information relevant to risk management or safe use of the product,
• result from legal changes that must be reflected in the SDS content.

The legislation does not specify an exact number of days – the key point is that notification must be made without unnecessary delay. For all changes, we recommend that they be clearly documented in Section 16 of the SDS, including the revision date and a brief description of the changes.

Summary

Distinguishing between updating and creating a new Safety Data Sheet is essential for proper legal compliance. A revision is appropriate when the classification, composition or legal framework of an existing product changes. A new SDS is required when the product is entirely new, with a different identity, composition or intended use.

High-quality and up-to-date documentation is the foundation for occupational safety and protection of health and the environment. Timely and accurate SDS updates also help companies avoid penalties and maintain credibility with partners.

Specialised software solutions such as SBLCore can assist you in making these decisions. They allow you to track classification changes, assess the impact of composition on risks, and automate document version control. This gives you confidence that your documentation complies with current legislation and that all changes are properly recorded and documented.

Note: This article is for informational purposes only and does not replace applicable legislation.

Recommended sources:

• Regulation (EC) No 1907/2006 (REACH)
• Regulation (EC) No 1272/2008 (CLP)
• Annex II to REACH – Requirements for compiling SDSs
• European Chemicals Agency (ECHA) – Guidance on SDS