Where to Get an SDS for a Handmade or Small Batch Product

Where do I get an SDS is one of the most searched questions among small makers, and it usually hides two different questions. The first is where to find the Safety Data Sheets for the ingredients they buy, which is answered by the suppliers, who must provide them under REACH for hazardous materials. The second is where to get an SDS for the product they make, a scented candle, a perfume oil or a room spray, which has a less welcome answer: nowhere, until it is written, because no database holds a Safety Data Sheet for a mixture that exists only in your workshop. The HSE, the Health and Safety Executive, sets out the GB requirements for the document, and the CLP Regulation sets the hazard classification for chemical substances and mixtures that the sheet must reflect.

This guide answers both questions: how to get complete raw material SDS from suppliers and what to do when they will not cooperate; why your finished product needs its own SDS and where that comes from; when self authoring is realistic and when it is not; what a professional SDS service does and costs; and which of your products need one at all.

Two different SDS problems

A Safety Data Sheet describes the chemical properties and potential hazards of a specific substance or mixture from a specific supplier. The sheet for a lavender essential oil describes that oil; the sheet for a soy wax describes that wax. Neither describes your lavender soy candle, which is a new mixture with its own composition and its own classification. Makers who search for a candle SDS and download the first plausible result are attaching a stranger's document to their product, which will fail an Amazon hazmat review if the name does not match and could misstate the hazards if it does. Separate the two problems and each becomes straightforward.

Getting SDS for the raw materials you buy

Ask the supplier; it is their obligation

Any supplier of a hazardous substance or mixture to a business must provide a Safety Data Sheet, free of charge, at or before first supply, and must update it when the classification changes. Reputable suppliers of fragrance oils, essential oils, surfactants, preservatives, lye and solvents publish SDS on their product pages, covering safe handling, use, storage and information for emergency responders, and send updates by email. If a sheet is not on the product page, email and ask; the answer should arrive in days. Non hazardous materials such as most butters and carrier oils may come with a non hazardous SDS or a technical data sheet, which is acceptable.

When the supplier will not or cannot provide one

Marketplace sellers of raw materials, overseas resellers and some very small suppliers sometimes cannot produce a compliant SDS, or send a document in another language, or an ancient MSDS. Ask once, clearly, for a current English language SDS in the sixteen section format. If it does not arrive, do not use the material in a product you intend to assess and sell. Downstream users, including your safety assessor, need the same information for the CPSR or TRA and its absence will stall the assessment; and a supplier who cannot document a hazardous chemical is a supplier whose material you cannot fully trust.

Online databases and their limits

Public SDS databases and chemical suppliers' libraries are useful for pure chemical substances, such as citric acid or sodium bicarbonate, and for branded products from large manufacturers of hazardous chemicals. They are not a source for your supplier's particular fragrance oil, whose composition is proprietary, and they are never a source for your finished product. Use them to understand a substance, not to document a mixture.

Getting an SDS for your finished product

Your finished product SDS must be written for your exact formulation. The process has three steps: gather the SDS and composition data for every raw material; classify the finished mixture under CLP by applying the classification rules to the components at their concentrations, which determines the hazard statements, pictograms and transport classification; and write all sixteen sections the 16 sections required in every compliant safety data sheet including first aid, storage, exposure controls, physical properties and transport information, consistent with that classification. The classification step is the one that requires expertise, because it decides everything else.

Self authoring

For a simple product that is clearly not hazardous, such as a plain soap or an unfragranced body butter, a maker with patience can complete an SDS template accurately, since most sections will state that the product is not classified and not regulated for transport. Free and paid SDS authoring software exists and will structure the document, but it relies on the user to enter correct component data and to interpret the classification output. The moment a product contains a meaningful level of fragrance, essential oil, alcohol or other classified ingredient, the classification requires judgement about concentration limits, additivity and specific concentration limits for individual substances, and errors have consequences: a misclassified flammable liquid shipped as unregulated is a transport offence, and a misclassified sensitiser undermines the label.

Professional authoring

An SDS authoring service takes your formulation and supplier documents, performs the classification, writes all sixteen sections in the format required for your markets, addressing safety and health requirements for safe use, and provides the transport classification. For fragranced and home fragrance products the classification is the same work that underpins the Toxicological Risk Assessment and the CLP label, so commissioning them together from one assessor is efficient and, more importantly, keeps the three documents consistent. Phoenix prepares finished product SDS for Amazon UK, Amazon US and EU and UK hazmat products.

What a professional SDS service needs from you

• The full formulation. Every ingredient with its exact percentage in the finished product.
• Raw material SDS. For every component, current and in English.
• Fragrance documents. IFRA certificate and allergen declaration for each fragrance or essential oil.
• Physical data. Appearance, odour, pH where relevant, flash point if known for alcohol based products, and pack sizes.
• Markets. Which countries and marketplaces you sell on, for language and regulatory versions.
• Product name and label. So the SDS matches the listing and the label.

Which of your products need a finished product SDS

Our guide to whether cosmetics need an SDS explains the exemption in detail, and the hazmat review guide explains what Amazon does with the document.

Reading a supplier SDS before you rely on it

Having a raw material safety data sheet is not the same as having a useful one. Before you file it, check a few things. Section 1 should name the actual supplier and product, not a generic description. Section 2 should give a GHS classification with coded statements documenting the health effects and other potential hazards; a fragrance oil claiming no hazards at all deserves scepticism, since most contain sensitisers. Section 3 should disclose the classified components with concentration ranges; a fragrance SDS with an empty section 3 will not support your finished product classification. Section 9 should give a flash point for anything that might be flammable. Section 16 should show a revision date within the last few years. If any of these are missing, ask the supplier for a better document before you build a product on the material.

Keeping your SDS library in order

A small brand quickly accumulates dozens of raw material sheets, and a disorganised library is nearly as bad as no library. Keep one folder per supplier, name files with the product, supplier and revision date, and maintain a simple register listing each material, the supplier, the SDS revision date and the date you last checked for an update. Review the register at least annually and whenever a supplier announces a reformulation. File a copy of each sheet in the relevant product's Product Information File or technical file, referenced by document number, so that an assessor or inspector can trace every ingredient's documentation. This is unglamorous work, but it is what turns a pile of PDFs into evidence of safe handling practices across your business.

What it costs and how long it takes

Raw material SDS are free from your supplier. A professionally authored finished product SDS is typically priced per product, with range pricing where several products share a base and differ only in fragrance, and turnaround is measured in days when the supplier documents are complete. The pacing factor is nearly always the fragrance paperwork. Software subscriptions for self authoring are priced monthly or annually and make sense for makers with many simple products and the time to learn classification; they make less sense for a maker with three fragranced products who needs them right first time.

A decision path

• Is it a raw material you bought? Get the SDS from the supplier. If they cannot provide one, change supplier.
• Is it your finished product and a cosmetic? No legal SDS requirement. Prepare an exemption sheet or an SDS only if a marketplace, carrier or business customer needs it, and an SDS if it is flammable or pressurised.
• Is it your finished product and not a cosmetic? Classify it. If hazardous, an SDS is legally required for business supply and a CLP label for consumers, alongside a TRA.
• Is it simple and clearly unclassified? Self authoring from a template is realistic.
• Does it contain fragrance, essential oil, alcohol or other classified ingredients? Have it professionally classified and authored, ideally with the TRA and label.

Common mistakes

• Downloading a similar product's SDS. It describes someone else's product and will fail a name check.
• Using a raw material SDS for the finished product. The fragrance oil sheet is not the candle sheet.
• Paying for SDS on products that do not need them. A body butter sold to consumers does not legally require one.
• Skipping the SDS on home fragrance. Candles and diffusers are not cosmetics and are not exempt.
• Inconsistent documents. An SDS classification that contradicts the TRA or the label.
• Never updating. A new fragrance or supplier means a new classification.

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)
• CLP Regulation (EC) No 1272/2008
• HSE guidance on safety data sheets
• HSE COSHH guidance
• General Product Safety Regulations 2005

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.