In the EU, suppliers of hazardous substances or mixtures must provide a safety data sheet that follows REACH Annex II, free of charge, no later than the first delivery. The SDS must be in the official language of each Member State where the product is sold, include content in all 16 sections, and be updated without delay when new hazard or risk management information becomes available.
The EU uses the same 16 headings as US HazCom 2024 but requires more information. Sections 12 to 15 must be completed, Section 3 must include EU-specific identifiers and limits, and some products require attached exposure scenarios. A US SDS can serve as a starting point, but it does not meet EU requirements on its own.
Last reviewed November 7, 2026. This page provides information only and does not constitute legal advice.
Who it applies to and the legal basis
Two EU regulations work together:
- REACH (Regulation (EC) No 1907/2006): Article 31 says who must supply an SDS and when. Annex II sets the format and content of each section. Annex II was last rewritten by Regulation (EU) 2020/878, which has applied to every EU SDS since January 1, 2023.
- CLP (Regulation (EC) No 1272/2008): the EU’s version of the GHS. It sets the classification criteria, the label, and the hazard and precautionary statements that SDS Section 2 must match.
An SDS is required for substances and mixtures classified as hazardous under CLP, for substances that are PBT or vPvB, and for substances on the REACH Candidate List of substances of very high concern (Article 31(1)). Manufacturers, importers, downstream users and distributors in the EU all pass it along the supply chain.
A US company selling into the EU typically works through an EU importer or distributor, who holds legal responsibility for the SDS. In practice, EU customers often request a compliant EU SDS directly from the US manufacturer.
Language and supply rules
- Language: the SDS must be in an official language of each Member State where the product is placed on the market, unless that Member State permits otherwise (Article 31(5)). See the next section for what that means in practice.
- Timing: the SDS must be provided free of charge, on paper or electronically, no later than the date the product is first supplied (Article 31(8)).
- Plain language: Annex II requires simple, clear and precise wording. Phrases such as “may be dangerous” or “harmless” are not permitted, and no information may contradict the classification.
- Page numbering: every page, including annexes, must be numbered and show either the total page count or that another page follows.
Hazard and precautionary statements must use the official CLP wording in each language, not a free translation.
Which languages your EU SDS needs
The requirement follows the product, not the company. What counts is the country where the product is placed on the market, meaning where your customer receives it, not where your business or your importer is based. A US manufacturer shipping one product to customers in five EU countries needs that SDS in each country’s official language.
The EU has 27 Member States and 24 official languages. In practice:
- Most countries need one language. Germany requires German, France requires French, Poland requires Polish and Italy requires Italian.
- Some countries have several official languages. Check with the national authority which ones are required:
| Country | Official languages |
|---|---|
| Belgium | Dutch, French, German |
| Luxembourg | French, German, Luxembourgish |
| Finland | Finnish, Swedish |
| Ireland | English, Irish |
| Malta | Maltese, English |
| Cyprus | Greek, Turkish |
- One language can cover several countries. A German SDS can serve Germany and Austria, and a French SDS can serve France and French-speaking Belgium, provided the content is valid for each country. Section 1 must show the correct supplier and emergency number, and Section 8 must list the exposure limits for each country of sale.
- The EEA follows REACH too. Norway, Iceland and Liechtenstein apply REACH and CLP, so Norwegian and Icelandic SDSs are required there. Great Britain does not; see our UK SDS requirements guide.
- “Unless the Member State provides otherwise.” Article 31(5) allows a country to accept another language. Do not assume English is accepted; confirm with your importer or the national authority first.
The entire SDS, including any exposure scenario annexes, must be translated, and every language version must have the same classification, values and revision date. The label follows the same rule: CLP requires it in the official language of each Member State where the product is sold.
EU SDS vs. US HazCom 2024 SDS: what changes
Both use the same 16 headings in the same order, but the EU SDS adds subsections and EU-specific content.
| SDS section | EU (REACH Annex II, CLP) | HazCom 2024 (US) |
|---|---|---|
| Language | An official language of every country where the customer receives the product: the 27 Member States plus Norway, Iceland and Liechtenstein. Five countries of sale usually means five language versions. Countries with several official languages, such as Belgium (Dutch, French, German), need a check on which apply. English is not accepted unless the country allows it (Article 31(5)). | English (other languages may be added) |
| 1. Identification | EU supplier details, including an email address for the competent person; the UFI if the mixture has one and it is shown on the SDS; “nanoform” in the identifier where relevant | US manufacturer, importer or other responsible party, plus an emergency number |
| 2. Hazard identification | CLP classification and label elements; 2.3 must state whether the substance, or any substance at 0.1% or more in a mixture, is PBT, vPvB or has endocrine-disrupting properties | HazCom 2024 classification and label elements |
| 3. Composition | Exact percentages or ranges; REACH registration numbers; specific concentration limits, M-factors and acute toxicity estimates where they exist. An ingredient’s identity can be withheld only with an ECHA-approved alternative chemical name. | Trade-secret concentrations use OSHA’s 13 prescribed ranges; no filing |
| 8. Exposure controls | EU indicative limit values and national limits for each country of sale; DNELs and PNECs for registered substances | OSHA PELs, ACGIH TLVs and other limits used by the preparer |
| 9. Physical and chemical properties | Split into 9.1 (basic properties) and 9.2 (information on physical hazard classes and other safety characteristics) | Item list revised in HCS 2024 |
| 11 and 12. Toxicological, ecological | 11.2 and 12.6 cover endocrine-disrupting properties | No equivalent subsection |
| 12–15. Ecological, disposal, transport, regulatory | Content required in all four sections | Headings required; OSHA does not enforce the content |
| Annex | Exposure scenarios attached for registered substances that need a chemical safety report | None |
For details on each section, see The 16 Sections of an SDS. For a side-by-side comparison of the US, EU and Canada, see Same Formula, Different SDS.
Key dates for new CLP hazard classes and label rules
CLP has changed twice since 2023, and both changes affect the SDS.
New hazard classes (Regulation (EU) 2023/707). CLP now has hazard classes that the GHS and HazCom 2024 do not: endocrine disruptors for human health and for the environment, PBT and vPvB, and PMT and vPvM. They appear in Section 2 and on the label.
| Product | Must be classified under the new classes by |
|---|---|
| New substances | May 1, 2025 |
| Substances already on the market | November 1, 2026 |
| New mixtures | May 1, 2026 |
| Mixtures already on the market | May 1, 2028 |
CLP revision (Regulation (EU) 2024/2865). The revised CLP entered into force on December 10, 2024. It adds new label formatting rules, including minimum font sizes, and new rules for advertising and online sales. Regulation (EU) 2025/2439, published December 3, 2025, postponed most of those label and advertising obligations to January 1, 2028. The new hazard classes were not postponed.
Updating and redistributing the SDS
Article 31(9) requires the supplier to update the SDS without delay when:
- New information becomes available that may affect risk management measures, or new information on hazards
- An authorisation is granted or refused
- A restriction is imposed
The updated SDS must be provided free of charge to everyone supplied in the previous 12 months. That is stricter than the US, where the updated SDS goes out with the next shipment.
There is no fixed review cycle, but the new CLP hazard classes mean every mixture already on the market must be checked against them by May 1, 2028, and its SDS updated wherever the classification changes.
Confidentiality, exposure scenarios and UFI
Confidentiality is limited. The EU has no prescribed trade-secret ranges like the US and Canada. To withhold an ingredient’s chemical identity, you request an alternative chemical name under CLP Article 24, and ECHA must approve it. This is allowed only when the substance has no EU workplace exposure limit and is classified only in lower-severity categories: physical hazards, acute toxicity Category 4, skin or eye irritation Category 2, STOT Category 2 or 3, or chronic aquatic Category 3 or 4 (CLP Annex I, 1.4.1).
Exposure scenarios. For registered substances that require a chemical safety report, the relevant exposure scenarios must be attached to the SDS as an annex (Article 31(7)). This is often called an extended SDS, or eSDS.
UFI. Mixtures classified for health or physical hazards require a poison centre notification and a unique formula identifier (UFI) on the label. If the UFI is also included on the SDS, it goes in Section 1.
How Valenc handles the EU
Valenc generates the EU SDS from the same product record as your US SDS, so one formulation supports every market you ship to.
- REACH Annex II format: the SDS follows the 2020/878 structure, including subsections 2.3, 9.1 and 9.2, 11.2 and 12.6.
- CLP classification: Valenc’s rules engine classifies under CLP, including the new hazard classes for endocrine disruptors, PBT/vPvB and PMT/vPvM.
- CLP labels: labels are generated from the same classified record as the SDS, in the language of each country.
- EU and national exposure limits: Section 8 lists EU limit values and the national limits for each country of sale, plus DNELs and PNECs where they exist.
- The language of each country: hazard and precautionary statements come from a curated phrase library in more than 25 languages, so every Member State version carries the same classification and values.
- Change management: when a formulation or rule changes, all affected US and EU SDSs are flagged for review.
- Approval before publication: your team reviews and approves each SDS before release.
View supported regions and languages, or request a demo using one of your products.
Frequently asked questions
Can I use my US SDS in the EU?
Not without modification. It must be translated into the official language of each country of sale, include CLP classification, complete Sections 12 to 15, add EU-specific subsections such as 2.3, 9.2, 11.2 and 12.6, and provide EU exposure limits and REACH registration numbers where applicable.
What language must an EU SDS be in?
An official language of each Member State where the product is sold, unless the country permits otherwise (REACH Article 31(5)). Selling in five countries typically requires five language versions. For countries with several official languages, such as Belgium and Luxembourg, confirm which languages are required.
What is Regulation 2020/878?
The Commission regulation that revised REACH Annex II, which sets the rules for SDS content. It has applied to all EU SDSs since January 1, 2023.
Are Sections 12 to 15 required on an EU SDS?
Yes. Unlike in the US, all four sections must be completed: ecological information, disposal, transport and regulatory information.
How quickly must an EU SDS be updated?
Without delay when new hazard or risk management information becomes available, or when an authorisation or restriction applies. The updated SDS must be provided to all recipients supplied in the previous 12 months.
Can I keep an ingredient confidential on an EU SDS?
Only with an alternative chemical name approved by ECHA under CLP Article 24, and only for substances in lower-severity hazard categories without an EU workplace exposure limit.
What is a UFI?
A unique formula identifier, required on the label of mixtures classified for health or physical hazards once they are notified to poison centres. If the UFI is included on the SDS, it goes in Section 1.
Sources
- Regulation (EC) No 1907/2006 (REACH): Article 31 and Annex II, EUR-Lex
- Commission Regulation (EU) 2020/878 amending REACH Annex II, EUR-Lex
- Regulation (EC) No 1272/2008 (CLP): Article 24 and Annex I, 1.4.1, EUR-Lex
- Commission Delegated Regulation (EU) 2023/707: new hazard classes, EUR-Lex
- Regulation (EU) 2024/2865: CLP revision, EUR-Lex
- Regulation (EU) 2025/2439: postponement of CLP label and advertising rules, EUR-Lex
- Revised chemical labelling regulation enters into force, European Commission, December 10, 2024
See an EU SDS built from one of your own products, in the languages you need, from the same record as your US SDS.
