SDS for Amazon UK, EU, US, Canada and Australia: What Differs by Marketplace

Here is a call we take most weeks. A home fragrance brand in the Midlands has a reed diffuser selling well on Amazon.co.uk. The SDS went through hazmat review without a murmur. They switch on Amazon.de, Amazon.fr and Amazon.ca, upload the same PDF, and within a fortnight three listings are blocked. Nothing about the product has changed. What changed is the country, and with it the law the safety data sheet is supposed to follow.

Amazon does not write its own SDS rules from scratch. It applies a short list of document checks of its own, then expects the sheet to be valid where the product is sold. In Great Britain that means UK REACH and GB CLP, with the HSE as regulator. In the EU it means EU REACH and EU CLP. In the US it is OSHA's Hazard Communication Standard, in Canada the WHMIS rules under the Hazardous Products Act and Regulations, and in Australia the Work Health and Safety Regulations and Safe Work Australia's code of practice. All five are built on the UN Globally Harmonized System (GHS), which is why the documents look alike. They are not interchangeable.

This guide goes store by store: what Amazon checks everywhere, what each jurisdiction adds, the classification differences that actually change the document, the language rules, and how to keep five versions in step without paying for five separate assessments.

What Amazon checks on every store

Amazon's Seller Central guidance sets out its own document rules, and they are the same whichever store you list on. To be accepted, an SDS must:

• have a creation or revision date within the past five years;
• show the same product name as the listing title, and the same manufacturer or brand name as the detail page;
• include all 16 standard sections, in the right order;
• be consistent with the hazard information on the product label;
• be in the language of the country where the product is sold. Amazon's own example is a seller in the US and Mexico needing one SDS in English and one in Spanish.

For a bundle or kit, Amazon wants a separate SDS for each chemical product inside it. An exemption sheet is only accepted for two categories: batteries and battery-powered products, and products without harmful chemicals. Submit one for anything else and it is rejected. Reviews normally take two business days, and if Amazon flags stock already sitting in a fulfilment centre, you get 14 business days to supply the documents before the inventory is disposed of at your cost.

The five-year rule is worth a comment. It is Amazon's rule, not a legal shelf life. In law an SDS has to be revised whenever significant new hazard or risk information appears, which can be much sooner. If you want the Seller Central side in more detail, our guide to Amazon hazmat review walks through the flags and how to clear them.

What stays the same everywhere

The GHS gives every jurisdiction the same 16 headings in the same order, the same hazard classes and categories for health and physical hazards, the same pictograms and largely the same hazard and precautionary statements. Transport classification sits on top of that and comes from the UN Model Regulations on the Transport of Dangerous Goods, so a flammable diffuser is UN1993 or UN1266 in Swindon and in Sydney alike. That shared skeleton is the reason one good master classification can be turned into five compliant documents rather than five separate pieces of work.

Marketplace by marketplace at a glance

Amazon UK: the GB sheet

Great Britain kept REACH and CLP after Brexit and now runs them separately as UK REACH and GB CLP, with the HSE as the agency. A GB sheet looks almost identical to an EU one, but there are three differences we check every time.

First, the format. When the EU replaced Annex II with Regulation (EU) 2020/878, the change applied from 1 January 2021, after the Brexit transition period, so it never became GB law. The GB Annex II on legislation.gov.uk is still the earlier text. A sheet in the newer EU layout usually contains everything the GB annex asks for, but section 15 must cite GB legislation, and subsection 1.1 asks for the product identifier as given on the label in English.

Second, classification. GB now has its own mandatory classification list. Where the HSE and the EU have reached different decisions for a substance, the GB sheet follows the GB list. GB has also not adopted the EU's new hazard classes for endocrine disruptors, PBT/vPvB and PMT/vPvM.

Third, the supplier in section 1 should be a GB-based business, and the emergency number has to work from the UK. Under UK REACH the sheet must be in English, though you may add other languages. Northern Ireland is the exception that catches people out; more on that below.

Amazon EU stores: one law, many languages

Every EU store applies the same REACH and CLP texts, and since 1 January 2023 every SDS supplied in the EU has had to follow Annex II as amended by Regulation 2020/878. That version adds a place for the UFI in subsection 1.1, specific information for nanoforms, and information on endocrine-disrupting properties in sections 2, 11 and 12.

It is also a moving target. The EU added new CLP hazard classes for endocrine disruptors, PBT/vPvB and PMT/vPvM through Delegated Regulation (EU) 2023/707. They apply to mixtures placed on the market from 1 May 2026, and mixtures already on the market have until 1 May 2028. If your fragrance contains a substance that picks up one of these classifications, the EU versions change and the GB version does not.

Language is where most rejections happen. Article 31(5) of REACH requires the official language or languages of the Member State where the product is placed on the market, unless that country says otherwise: German for Amazon.de, French for Amazon.fr, Italian for Amazon.it, Spanish for Amazon.es, Dutch for Amazon.nl, Polish for Amazon.pl, Swedish for Amazon.se, English for Amazon.ie. Belgium has three official languages, so check which it accepts before you list on Amazon.com.be. Section 8 should carry the occupational exposure limits of the country concerned, and section 1 needs an EU-established supplier. For a UK brand, that is normally its EU importer.

If you use Pan-European FBA, Amazon can move stock into fulfilment centres in several countries. Have every language version ready before you enrol, not after the first transfer.

Where the product is a hazardous mixture, it will usually need a poison centre notification and a UFI on the label too. Our guide to poison centre notification and the UFI covers who files it and when.

Amazon.com: the OSHA sheet

The US adopted the GHS through OSHA's Hazard Communication Standard. The 2024 update aligned it with GHS Revision 7 and took effect on 19 July 2024. On 15 January 2026 OSHA pushed every compliance date back by four months. Manufacturers, importers and distributors had to update sheets for substances by 19 May 2026 and have until 19 November 2027 for mixtures, and until then either the 2012 or the 2024 version of the standard may be followed. Most finished consumer products are mixtures, so the 2027 date is the one to plan around.

The US sheet differs from a European one in a few predictable ways. OSHA does not regulate environmental hazards, so aquatic toxicity, which drives many fragrance classifications in Europe, does not set the signal word or pictograms in section 2. Sections 12 to 15 must still be present, but OSHA does not enforce their content. The US includes Flammable Liquid Category 4 (flash point above 60 °C and up to 93 °C), which EU and GB CLP do not use, and it has a category for hazards not otherwise classified. Section 1 must give the name, address and telephone number of the US manufacturer, importer or other responsible party, plus an emergency number. The sheet must be in English.

Section 14 should reference the US Department of Transportation rules in 49 CFR alongside IATA and IMDG. One wrinkle: for US domestic ground transport, a flammable liquid with a flash point of 38 °C or above can be reclassed as a combustible liquid, and liquids flashing between 60 °C and 93 °C are combustible liquids rather than Class 3. That changes how the product ships by road inside the US. It does not change the UN classification used for air and sea.

Phoenix prepares SDS for Amazon USA in OSHA format, built from the same classification as your UK and EU versions.

Amazon.ca: WHMIS, in two languages

Canada applies the GHS through WHMIS, under the Hazardous Products Act and the Hazardous Products Regulations. The amended HPR, aligned with GHS Revision 7 and parts of Revision 8, came into force on 15 December 2022, and the three-year transition ended on 14 December 2025. Every hazardous product now needs a classification, SDS and label that meet the amended rules. Health Canada has said it will focus on compliance promotion until 19 July 2027 before moving to risk-based enforcement, but that is a grace period for enforcement, not a reason to wait.

Two requirements cause most problems. The SDS must be in English and French, either as one bilingual document or as two unilingual documents supplied together. And it must carry a Canadian supplier identifier: the Canadian importer or distributor, not just the foreign manufacturer. An importer can keep the foreign supplier's name only when the product is imported for use in its own workplace, which is not the Amazon case.

WHMIS covers physical and health hazards only. There is no environmental hazard class, so the European aquatic classification has no place in a Canadian section 2. Canada and the US also differ on some details: concentration ranges for trade secrets, the content of section 11, update periods (90 days for an SDS in Canada after significant new data, three months in the US) and a handful of hazard classes. Section 14 should cite the Transportation of Dangerous Goods Regulations alongside the international codes.

See our Amazon Canada SDS service for bilingual WHMIS sheets.

Amazon.com.au: the WHS sheet

Australia implements the GHS through the model Work Health and Safety Regulations, adopted by each state and territory, and through Safe Work Australia's model Code of Practice on preparing SDS. GHS Revision 7 has been mandatory since 1 January 2023, and an SDS must follow it even where older stock still carries a Revision 3 label.

The sheet needs the name of the Australian manufacturer or importer, with an Australian address and business telephone number, plus an emergency contact number. Australia also takes a different view of what counts as hazardous. A chemical is not a hazardous chemical under WHS if its only classifications are acute toxicity Category 5, skin irritation Category 3, aspiration hazard Category 2, flammable gas Category 2, or the aquatic or ozone categories. So, as in the US, environmental classification does not make a product hazardous at work, though it still matters for transport.

The date to watch is 1 December 2026. From then, Australia's workplace exposure standards (WES) become workplace exposure limits (WEL). Some values change and new substances are added, so section 8 of an Australian sheet should cite the limits that apply. Section 14 should reference the Australian Dangerous Goods Code.

Northern Ireland, Switzerland and other edge cases

Northern Ireland follows EU REACH and EU CLP under the Windsor Framework. A product shipped there needs EU-compliant documents, including a poison centre notification where one applies, even if it is sold through Amazon.co.uk. Switzerland has no Amazon store of its own, but Swiss buyers can order from Amazon.de and others. Switzerland applies its own Chemicals Ordinance, closely aligned with EU CLP, with Swiss supplier details on the SDS. Further afield, Amazon.com.mx, Amazon.co.jp and Amazon.sg each bring their own national version of the GHS and their own language. The principle holds everywhere: the structure travels, while the legal references, language and supplier details do not.

Classification differences that change the document

• Environmental hazards. Regulated hazard classes in GB and EU CLP. Not hazard classes under OSHA or WHMIS, and they do not make a product hazardous under Australian WHS. The data still belongs in section 12, and in section 14 where the product is environmentally hazardous for transport.
• Flammable liquids. GB and EU CLP use Categories 1 to 3. The US, Canada and Australia also use Category 4, so a liquid with a flash point between 60 °C and 93 °C can carry a classification in North America that it does not have in Europe.
• New EU hazard classes. Endocrine disruptors, PBT/vPvB and PMT/vPvM exist in EU CLP only. They do not exist in GB, US, Canadian or Australian law.
• Harmonised classifications. The GB mandatory list and the EU harmonised list are now maintained separately and can differ for individual substances, including some fragrance materials.
• Catch-all categories. The US has hazards not otherwise classified. Canada has physical and health hazards not otherwise classified, which carry label and SDS duties the US does not impose.
• Transport. The UN number, class and packing group should be identical on all five versions. Only the regulations cited change.

Language: what "translated" really means

Amazon UK, Amazon.com and Amazon.com.au take English. Amazon.ca needs English and French. Each EU store needs its country's official language. The word that matters is translation in the technical sense. In the EU, hazard and precautionary statements have official wording in every language, set out in the CLP annexes, and the translated sheet must use that wording, not a paraphrase. A sheet run through a machine translator will usually get the standard phrases wrong, and a reviewer comparing it with the label will notice. Translate from the master, use the official phrase sets, and keep the version numbers aligned.

Cosmetics: legally exempt, commercially required

Here is the twist for beauty brands. In the UK and EU, finished cosmetic products intended for the end user are outside the SDS provisions of REACH and outside CLP altogether. In Canada, cosmetics and consumer products are excluded from WHMIS, and consumer chemical products fall under the Consumer Chemicals and Containers Regulations, 2001 instead. In the US, cosmetics packaged for retail sale are exempt from the Hazard Communication Standard. In Australia, suppliers do not have to provide an SDS with a consumer product. We explain the UK and EU position in do cosmetics need an SDS?.

Amazon's dangerous goods team works to a different brief. It needs to know how to store, handle and ship the product, so it can still ask for an SDS for an alcohol-based perfume, an aerosol dry shampoo or a nail product. An exemption sheet is only accepted if the product genuinely contains no harmful chemicals. For a cosmetic, the practical answer is an SDS that states the product's regulatory status clearly and still gives accurate physical, transport and handling data. Home fragrance is different. Reed diffusers, room sprays and wax melts are chemical mixtures, not cosmetics, and their SDS is a legal requirement where they are supplied to businesses.

One master classification, five outputs

The efficient way to do this is to classify the finished product once, from the full formulation and current supplier SDSs, and keep that classification as the master. Each marketplace version is then generated from it by changing only what the jurisdiction requires: the legal references, the language, the supplier block and emergency number, the exposure limits in section 8, the regulatory information in section 15, the transport regulations cited in section 14, and the hazard classes that a given system does or does not recognise. Composition, test data and the UN transport classification stay the same.

When the formula changes, the master is updated and every version is reissued together with the same revision date. Sellers who buy each country's SDS from a different provider end up with five documents that disagree on flash point or composition, and Amazon's reviewers do compare them.

That is how we work for multi-store sellers. We produce the Amazon UK, Amazon EU, Amazon USA, Amazon Canada and Amazon Australia versions from one classification, and the same classification supports your label and, where needed, the poison centre notification.

A worked example: one reed diffuser, five sheets

Take a 100 ml reed diffuser: fragrance in a glycol ether and alcohol base, flash point 48 °C. The master classification makes it a Category 3 flammable liquid and a skin sensitiser because of the allergens in the fragrance, with a long-term aquatic hazard from two of the fragrance materials. For transport it is UN1993, flammable liquid, n.o.s., Class 3, packing group III, and that line is the same on every version.

• EU (German, French, Italian and so on). Annex II as amended by 2020/878. Flammable, sensitiser and aquatic pictograms. The UFI on the label, and usually repeated in subsection 1.1. The EU importer in section 1. Country exposure limits in section 8.
• GB. The same hazards, checked against the GB mandatory list. English. A GB supplier. GB legislation in section 15. No UFI.
• US. Flammable liquid and sensitiser in section 2. The aquatic data moves to section 12 and does not set a pictogram. A US responsible party. 49 CFR in section 14.
• Canada. The same health and physical classes as the US, with no environmental class. Bilingual English and French. A Canadian importer. TDG in section 14.
• Australia. Flammable liquid and sensitiser. The aquatic classification does not make it hazardous under WHS but stays in sections 12 and 14. An Australian importer and phone number. WEL in section 8 from 1 December 2026. The ADG Code in section 14.

Five documents, one set of facts. When a reviewer on any store looks at the sheet next to the label, the two agree.

Common cross-marketplace mistakes

• Uploading the UK SDS everywhere. The language, legal references and supplier will be wrong outside GB.
• English only for Canada. French is mandatory.
• A UK address on an EU SDS. The supplier must be established in the EU.
• Aquatic pictograms on a US or Canadian section 2. They are not hazard classes there. Report the data in section 12.
• Different transport data on different stores. The UN classification is international, and a mismatch tells the reviewer one of the sheets is wrong.
• A product name that does not match the listing. Amazon checks the product and brand name on the SDS against the detail page, translated where the listing is.
• A sheet older than five years. Valid in law, perhaps, but Amazon will reject it.

Related reading

• Amazon hazmat review: why your listing was flagged and how to clear it
• Do cosmetics need an SDS?
• MSDS vs SDS: what changed under GHS
• Where to get an SDS for a handmade or small batch product
• Poison centre notification (PCN) and the UFI code
• Room sprays and reed diffusers: toxicological risk assessment
• Cosmetic marketplace compliance documents
• All regulatory compliance articles

Myths we hear

• An SDS that passed on Amazon.co.uk will pass everywhere. Amazon asks for the language of the country of sale, and each store's reviewers expect that country's legal references and supplier details.
• Google Translate is good enough for the EU versions. Hazard and precautionary statements have official wording in every EU language. A free translation will not match it.
• A US sheet works in Canada because both follow the GHS. Canada needs French as well as English and a Canadian supplier identifier, and the two systems still have documented variances.
• Environmental hazards must appear in section 2 everywhere. Only GB and EU CLP regulate them as hazard classes. In the US, Canada and Australia they belong in section 12, and in the transport data where relevant.
• Cosmetics are exempt, so Amazon cannot ask for an SDS. The legal exemptions are real, but Amazon's dangerous goods team can still ask for an SDS or an exemption sheet before it will store and ship the product.

What to do this week

1. List every Amazon store you sell on, plus every EU country pan-European FBA could ship to.
2. Check the revision date, product name and brand on each SDS you have uploaded against the live listing.
3. Confirm you have a supplier in section 1 for each region: GB, EU, US, Canada and Australia.
4. Commission proper translations of the EU versions and a French version for Canada.
5. Check Australian section 8 against the workplace exposure limits that apply from 1 December 2026.
6. Diarise the US mixtures deadline of 19 November 2027 for HazCom 2024 updates.

Frequently asked questions

Official sources and legislation

• Amazon Seller Central: Dangerous goods (hazmat) required information and documentation (SDS requirements)
• UK REACH Annex II: requirements for safety data sheets (GB)
• GB CLP Regulation (EC) No 1272/2008 as it applies in GB
• HSE: Safety data sheets
• HSE: GB mandatory classification and self-classification
• EU REACH Regulation (EC) No 1907/2006 (Article 31, Annex II)
• Commission Regulation (EU) 2020/878 amending REACH Annex II
• EU CLP Regulation (EC) No 1272/2008
• Delegated Regulation (EU) 2023/707: new CLP hazard classes (ED, PBT/vPvB, PMT/vPvM)
• OSHA Hazard Communication Standard
• Federal Register, 15 January 2026: OSHA extends HCS 2024 compliance dates
• Health Canada: Supplier hazard communication requirements under WHMIS
• Health Canada: Amended Hazardous Products Regulations (GHS Rev. 7)
• CCOHS: WHMIS and US HCS 2024 variances
• Safe Work Australia: Safety data sheets
• Safe Work Australia: Adoption of GHS 7
• Safe Work Australia: Workplace exposure standards and limits (WEL from 1 December 2026)
• Regulation (EC) No 1223/2009 on cosmetic products