Duties and Liability for Safety Data Sheets

Responsibility for Safety Data Sheets (SDS)

Basic Principles

Safety Data Sheets (SDS) are a central tool for ensuring the safe handling of chemical substances and mixtures throughout the supply chain. Nevertheless, there is often a misunderstanding that responsibility for their content remains with the original supplier.

According to the guidelines of the European Chemicals Agency (ECHA), it is clearly established that all actors in the supply chain who provide safety data sheets are responsible for their content—regardless of whether they created the document themselves or adopted it from a supplier.

Responsibilities in the Supply Chain

Providing a safety data sheet carries clear legal responsibility.
Companies that distribute an SDS must ensure that all information is accurate, up-to-date, and relevant to the specific product. A purely formal transfer without verification (“copy-paste”) does not meet the regulatory requirements.

Every link in the supply chain is obliged to:

Validate the received information,
Adapt it, if necessary, to the actual product and customer base, and
Ensure that the requirements of REACH and CLP are fully met.

Practical Implementation

To ensure compliance, the following approach is recommended:

Verification of the provided information: All data from the supplier’s SDS must be checked for completeness and accuracy.
Adaptation to the own product: Changes in composition, labeling, or use require an update of the safety data sheet.
Documented responsibility: The distributor remains responsible for the content of the transmitted SDS, even if relying on information from their suppliers.

Conclusion

Responsibility for safety data sheets cannot be transferred.
Companies placing substances or mixtures on the market must ensure that the information provided complies with legal requirements and guarantees the safe use of the products.

A solid knowledge of the relevant regulations, as well as regular training, is essential to ensure the quality and legal security of safety data sheets in the long term.

This summary is based on information from the European Chemicals Agency (ECHA).

"Suppliers at downstream stages of the supply chain must provide a safety data sheet. In doing so, they must review the information received from their suppliers, ensure its adequacy, and, if necessary, supplement it to meet the specific requirements of their customers."