{"id":8681,"date":"2022-04-13T09:00:40","date_gmt":"2022-04-13T13:00:40","guid":{"rendered":"http:\/\/blog.thecompliancecenter.com\/?p=8681"},"modified":"2025-09-08T01:52:27","modified_gmt":"2025-09-08T05:52:27","slug":"ghs-sds-ingredient-disclosure","status":"publish","type":"post","link":"https:\/\/www.thecompliancecenter.com\/ca\/help-center\/articles\/ghs-sds-ingredient-disclosure\/","title":{"rendered":"GHS SDS Ingredient Disclosure"},"content":{"rendered":"

This post was originally published in February 2018 and has been updated in April 2022 for accuracy.<\/em><\/p>\n

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Another SDS ‘Headache’<\/h2>\n

If you are supplying chemical products that require Safety Data Sheets (SDS\u2019s) to multiple countries, you are also likely to know this headache well.<\/span>\u00a0<\/span><\/p>\n

With the implementation of the Globally Harmonized System of Classification & Labeling (GHS) around the world progressing, issues are beginning to appear which emphasize points where\u2026. Maybe requirements are not so \u2018harmonized\u2019. One such issue, is ingredient disclosure requirements on SDS\u2019s for mixtures across different regions of the world.<\/span>\u00a0<\/span><\/p>\n

The United Nation\u2019s (UN\u2019s) GHS system, does contain some standardized recommendations for SDS, including that SDS\u2019s should be provided only for chemicals classified as \u2018hazardous\u2019, SDS\u2019s should contain basic minimum information (e.g., 16 sections with specific headings), as well as more detailed recommended guidance on how to prepare each section of the SDS.<\/span>\u00a0<\/span><\/p>\n

Ingredient disclosure recommendations, in particular, appear in Annex 4 of the GHS. In general, the GHS recommends that for a mixture classified as hazardous, the SDS should list all \u2018hazardous\u2019 ingredients, which are individually hazardous to health or the environment, when the ingredients are present above concentration cutoff levels. There\u2019s several parts of that\u202f<\/span>general<\/span><\/i>\u202frequirement, which can be viewed as a \u2018can of worms\u2019.<\/span>\u00a0<\/span><\/p>\n

Are the cutoff levels the same for each region of the world? How should one handle ingredient disclosure when you are in a region that doesn\u2019t regulate environmental hazards on SDS\u2019s? Are \u2018non-hazardous\u2019 chemical mixtures really not required to have an SDS?<\/span>\u00a0<\/span><\/p>\n

The United States, Canada, and Europe \u2013 Where they Differ<\/h3>\n

The European Union (EU)<\/h4>\n

In the EU, detailed SDS requirements appear in Annex II to the REACH regulation [<\/span>Regulation (EC) No. 1907\/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals<\/span><\/i>]. The SDS requirements in REACH work closely in conjunction with the EU\u2019s GHS regulation [<\/span>Regulation (EC) No. 1272\/2008 on classification, labelling and packaging of substances and mixtures<\/span><\/i>, or the \u2018CLP\u2019].<\/span>\u00a0<\/span><\/p>\n

In comparison to the UN\u2019s GHS general SDS requirements above, the EU\u2019s REACH and CLP requirements, include additional requirements for SDS ingredient disclosure. For mixtures which are classified as \u2018hazardous\u2019, ingredients which are hazardous to health or the environment, are required to be disclosed if they are present above a multitude of concentration cutoffs.<\/span>\u00a0<\/span><\/p>\n

Perfect! This requirement \u2018basically\u2019 is the same as the UN\u2019s recommendation. Note the comment \u2018\u2026 a multitude of concentration cutoffs\u2019. REACH has a list of \u2018generic\u2019 concentration cutoffs for ingredients, but there are a number of other cutoff requirements in different sections of the CLP regulation to consider as well. These include:<\/span>\u00a0<\/span><\/p>\n