Safety Data Sheets

SDS authoring and review

We write new SDSs for substances and mixtures entering the market, and we review and rewrite existing ones that are outdated, incomplete, or no longer aligned with current regulation. An SDS that was accurate under an older harmonised classification may now carry incorrect hazard statements, wrong transport classifications, or missing exposure scenario references.

Our authoring process begins with the composition, supplier SDSs, and any available toxicological or ecotoxicological data. Classification is checked independently rather than copied from existing documents. We cross-reference Annex VI of CLP for harmonised entries and document the basis for any self-classification. The 16-section format follows Commission Regulation (EU) 2020/878, which updated the SDS requirements and has applied since January 2023.

For UK-registered products we apply the equivalent GB-specific requirements. GB CLP has diverged from EU CLP since Brexit and continues to do so as ECHA and the HSE make independent classification decisions. A single-version SDS does not cover both markets.

Extended safety data sheets

When a substance requires a Chemical Safety Report under REACH Article 14, the SDS must be accompanied by exposure scenarios developed in that CSR and annexed to the document. This format applies to registered substances supplied above the registration tonnage threshold and to mixtures containing them above the relevant concentration cut-off.

Writing a compliant extended SDS entails aligning the exposure scenarios with what downstream users actually do. A communication gap in the chain could be present where contributing scenarios from a substance supplier do not cover your mixture's uses or your customers' activities, . We help resolve that alignment, either by working with the contributing scenarios or by preparing downstream user chemical safety reports where the standard scenarios do not cover the use case.

We also support distributors and downstream users in communicating exposure scenarios further down the chain and advising customers on how to handle situations where their use falls outside the supplied conditions.

Keeping SDSs current

An SDS needs updating when a substance's classification changes, when new hazard information becomes available, when a substance is added to the SVHC Candidate List, when a relevant restriction under Annex XVII comes into force, or when authorisation status changes. Under REACH Article 31(9), you are required to supply the updated version to all recipients who received the substance or mixture in the preceding 12 months.

We monitor ECHA regulatory developments, new Annex VI harmonised classification entries, and Candidate List updates, then identify what affects your product portfolio. For clients on a maintenance retainer, we handle updates and version control directly.

Multilingual SDSs

Under REACH Article 31(5), the SDS must be provided in the official language or languages of each Member State where the substance or mixture is placed on the market. The practical scope depends on your distribution footprint, but the requirement can cover all 24 official EU languages. We coordinate professionally translated SDSs across all EU official languages and UK English, reviewed by translators with chemical and regulatory background, and we maintain version parity across the full language set.

Translating an SDS is delicate work. A document rendered without regulatory context can carry technically inaccurate phrasing in Section 2, incorrect signal words, or mistranslated precautionary statements. We review language versions to ensure chemical and regulatory accuracy.

SDS collection from your suppliers

If you buy in raw materials, intermediates, or formulation components, you need a current and compliant SDS for each one. During day-to-day operations, supplier SDSs are received in different formats, in different languages, at different times, and with varying levels of compliance quality. Tracking what you have, what is missing, and what has changed is a substantial ongoing burden once a product portfolio reaches a noticeable size.

LIRK NOR takes on the supplier SDS collection function on behalf of clients. We contact suppliers, request documents to the correct standard, follow up on non-responses, and screen received SDSs for completeness and regulatory compliance. Where a received SDS has a classification issue or a composition gap, we communicate that back to the supplier with specific correction requests. We maintain a tracked repository of received documents with status notes and version monitoring, giving you a current view of your SDS holdings at any point.

SDS management and portfolio audits

If your internal SDS process has grown incrementally and you are not confident it reflects your current product range and obligations, a portfolio audit is the right starting point. We map your product list against your SDS holdings, identify gaps and outdated versions, assess the classification and regulatory accuracy of a representative sample, and produce a prioritised remediation plan.

For companies that need an ongoing outsourced SDS function, we offer a retainer model covering new authoring as products are introduced, scheduled reviews, supplier collection management, and distribution record-keeping. Scope is defined by your product and supply chain footprint.

We also provide practical guidance for companies evaluating or implementing SDS management software. If you are selecting a platform or migrating between systems, we can advise on the regulatory content requirements the system needs to support and review whether its output meets current standards.

Sector-specific SDS requirements

If your internal SDS process has grown incrementally and you are not confident it reflects your current product range and obligations, a portfolio audit is the right starting point. We map your product list against your SDS holdings, identify gaps and outdated versions, assess the classification and regulatory accuracy of a representative sample, and produce a prioritised remediation plan.

For companies that need an ongoing outsourced SDS function, we offer a retainer model covering new authoring as products are introduced, scheduled reviews, supplier collection management, and distribution record-keeping. Scope is defined by your product and supply chain footprint.

We also provide practical guidance for companies evaluating or implementing SDS management software. If you are selecting a platform or migrating between systems, we can advise on the regulatory content requirements the system needs to support and review whether its output meets current standards.

SDS interpretation and internal training

Regulatory and quality teams who work with SDSs day to day benefit from understanding the document beyond its surface content. We run internal workshops for product compliance, QA, and procurement teams covering how SDSs are structured, what the 16 sections actually require, how to read an extended SDS, and how to identify common errors or gaps in supplier documents. These sessions are designed for people who handle SDSs regularly but are not regulatory specialists.

We also support procurement and sourcing teams in building SDS-related requirements into supplier qualification frameworks, so that SDS quality becomes part of how incoming materials are assessed before they enter the supply chain.