MSDS vs SDS: What Changed Under GHS and What UK Sellers Need Now

Search for MSDS UK and you will find thousands of documents still carrying the old name, decades after it stopped being the correct one. The Material Safety Data Sheet was the document suppliers of chemicals used to describe hazards and safe handling before the world agreed a common system. That system, the Globally Harmonised System of Classification and Labelling of Chemicals (classification and labeling, in US usage), was adopted in the UK and EU through the CLP Regulation and REACH, with the HSE as the GB authority, and in the United States through OSHA's Hazard Communication Standard. It renamed the document the Safety Data Sheet and fixed its format.

This guide explains what changed and why, what a compliant SDS must contain, whether a document headed MSDS is still acceptable, who has to provide an SDS to whom in the UK, and what this means for cosmetic and home fragrance makers who both receive SDS from suppliers and are asked for them by marketplaces.

Where the MSDS came from

Before harmonisation, each country and often each industry had its own conventions for communicating chemical hazards. In the United States, OSHA required suppliers to provide a Material Safety Data Sheet but did not prescribe its format, so sheets varied from a single page to a dozen, with sections in any order and hazard descriptions in the supplier's own words. Europe had a somewhat more structured document under earlier directives, but classification criteria differed from the US and from other regions. The same chemical product could be labelled toxic in one country and harmful in another, and a worker moving between employers, or a shipment moving between countries, met a different vocabulary each time.

What the GHS changed

The Globally Harmonised System, developed through the United Nations, standardised three things: the criteria for classifying a substance or mixture into hazard classes and categories, communicating the potential hazards of each; the label elements, meaning the pictograms, signal words and hazard and precautionary statements; and the format and content of the Safety Data Sheet. The EU implemented it through CLP for classification and labelling and through REACH Annex II for the SDS format, with the UK retaining both after leaving the EU. The US implemented it through the 2012 revision of the Hazard Communication Standard. Canada, Australia and most major economies followed. The document was renamed the Safety Data Sheet, and the M was dropped because the harmonised sheet covers hazards beyond the material's own properties, including safe transport and disposal.

The sixteen sections

The order is mandatory and the section headings are fixed. A document with these sixteen headings in this order is recognisable as an SDS for any chemical product in any jurisdiction; a document without them is not, however thorough it may be. Knowing how to read an SDS quickly, section by section, is as valuable as knowing how to write one.

Is an old MSDS still valid?

No, not as the legal document. In the UK and EU a supplier of a hazardous substance or mixture must provide an SDS in the REACH Annex II format, and a pre GHS MSDS, in the old MSDS format, does not meet it. In the US, OSHA required all SDS to be in the GHS format by 2015. In practice, a document headed MSDS is a signal that the underlying classification may predate the GHS criteria, so its hazard statements may be in the old wording and its classification may be wrong under current rules. If a supplier sends you an MSDS, ask for a current SDS. If they cannot provide one, question whether they are a supplier you should be buying hazardous materials from.

Why the format matters more than it seems

Sellers sometimes argue that a well written MSDS contains everything a reader needs and the fixed format is bureaucracy. The harmonised format exists because the readers of an SDS are rarely the people who wrote it: a warehouse operative in another country, a carrier deciding how to load a vehicle for safe transport, a poison centre or other emergency responders taking an emergency call and following the sheet's emergency procedures, an inspector comparing the sheet against a label. Each needs to find first aid, transport or classification information in seconds, in the same place on every sheet, in standard wording that translates exactly. A one off document, however careful, defeats that purpose, which is why regulators and marketplaces treat format as substance rather than style.

Who must provide an SDS in the UK

Under REACH regulation, the supplier of a chemical substance or mixture must provide an SDS to the recipient when the substance or mixture is classified as hazardous under CLP, when a mixture is not classified but contains certain hazardous substances above set concentrations, or when the substance is persistent, bioaccumulative and toxic or on the candidate list. The duty runs to professional recipients, not to consumers, and consumers may request one. Employers then use SDS under COSHH to assess and control risks and protect workers. So the chain is: manufacturer or importer classifies and writes the SDS; distributor passes it on; user relies on it.

What this means for cosmetic and home fragrance makers

As a buyer of raw materials

Every hazardous raw material you buy should come with a current SDS in the sixteen section format, and you should hold it for your own COSHH risk assessment, for your safety assessor, and for your Product Information File. Fragrance oils, essential oils, preservatives, surfactants, sodium hydroxide, solvents and many actives are hazardous chemicals that are classified and must be accompanied by an SDS. Butters and carrier oils often are not classified and may come with a non hazardous SDS or a technical data sheet instead, which is acceptable.

As a seller of finished products

Finished cosmetics for the end user are exempt from the REACH SDS requirement, but marketplaces and carriers ask for an SDS anyway for transport and storage classification, especially for flammable or pressurised products, and a candle, wax melt or diffuser is not a cosmetic and needs an SDS if classified. Any SDS you provide for a finished product must be in the current 16 section format; an MSDS style document will be rejected in a hazmat review. Our guide to whether cosmetics need an SDS and our Amazon hazmat review guide cover this in detail.

The SDS and your other documents

It helps to see where the SDS sits among the documents a maker holds. Raw material SDS are inputs to your safety assessment and to your workplace risk assessment. The Cosmetic Product Safety Report or the Toxicological Risk Assessment is the document that establishes your finished product is safe in use. The CLP label, for non cosmetic products, communicates hazards to consumers. The finished product SDS, where one is needed, communicates the same hazards to businesses and carriers. None of these substitutes for another: an SDS does not prove safety, a CPSR does not classify for transport, and a label does not replace either. Makers who understand the roles stop asking whether the SDS is the same as the safety report, and start asking which of the documents each product actually needs.

How to tell a good SDS from a bad one

• Format. Sixteen sections (16 sections in total), in order, with the standard headings.
• Classification. Section 2 uses GHS hazard classes and categories and the standard H and P statements documenting health effects, not free text.
• Pictograms. The red diamond GHS pictograms, not the old orange squares.
• Composition. Section 3 lists the hazardous components with their classifications and concentration ranges.
• Transport. Section 14 gives the UN number  a unique number assigned to each dangerous substance  proper shipping name, class and packing group, or states not regulated.
• Currency. Section 16 shows a recent revision date and what changed, including any new hazard information.
• Consistency. The classification in section 2, the components in section 3 and the label on the container agree.

A short history for context

The Material Safety Data Sheet became a legal requirement in the United States in the 1980s under the original Hazard Communication Standard, which required suppliers to disclose hazards but left the format to them. Europe introduced a more structured safety data sheet under its dangerous preparations legislation in the 1990s, with a sixteen heading layout that later became the GHS model. The United Nations work on a Globally Harmonised System concluded in the early 2000s, and adoption followed through the decade: the EU through CLP from 2009 with full application to mixtures by 2015, the US through the 2012 revision of the Hazard Communication Standard with a 2015 deadline, and Canada through WHMIS 2015. The UK carried the EU framework into domestic law at the end of the transition period. So the MSDS has been superseded for roughly a decade everywhere that matters, and its persistence in search results reflects old documents rather than current law.

What changed in the content, not just the name

• Classification criteria. Standardised hazard classes and categories with defined cut off values replaced national criteria that disagreed with each other.
• Label elements. Nine red diamond pictograms, two signal words and a fixed set of coded hazard and precautionary statements replaced varied national symbols and free text.
• Mixture classification rules. Defined methods for classifying a mixture from its components, including additivity and specific concentration limits.
• Fixed section order. The sixteen sections in a mandatory sequence so that information is always in the same place.
• Transport alignment. Section 14 aligned with the international dangerous goods rules for safe transport.
• Revision tracking. Section 16 records the date and nature of changes, so a reader can tell whether the document is current.

Common misconceptions

• MSDS and SDS are different documents. They are the same kind of document under old and new rules; only the SDS is currently valid.
• Any product needs an SDS. Only hazardous substances and mixtures supplied to professionals do, plus the exceptions above; finished cosmetics are exempt.
• An SDS proves a product is safe. It communicates hazards; safe use and safety in use are established by a risk assessment such as a CPSR or TRA, not by the SDS itself.
• A one page hazard summary is an SDS. It is not, without the sixteen sections.
• The format does not matter if the information is there. The format is the law; the fixed structure is the point of harmonisation.

Phoenix prepares current format SDS for Amazon UK, Amazon US and EU and UK hazmat products, and can review a supplier's document if you are unsure whether it is acceptable.

Related reading on the Phoenix blog

• Do cosmetics need an SDS?
• TRA for candles and wax melts
• Poison centre notification (PCN) and UFI explained
• All regulatory compliance articles

Phoenix services mentioned in this article

• Safety Data Sheets for Amazon USA products
• Safety Data Sheets for Amazon UK products
• Safety Data Sheets for hazmat products, EU and UK
• Toxicological Risk Assessment for fragranced products
• Cosmetic Product Safety Report, single variant
• Expert regulatory consultation
• Contact Phoenix

Official sources and legislation

• REACH Regulation (EC) No 1907/2006 (retained UK version), Annex II
• CLP Regulation (EC) No 1272/2008
• HSE guidance on safety data sheets
• HSE COSHH guidance
• OSHA Hazard Communication Standard

About the author

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.