Do Cosmetics Need an SDS? When a Safety Data Sheet Is (and Is Not) Required

Three emails from one week are a good way into this question.

A soap maker orders a litre of lavender essential oil and gets a bottle with no paperwork. A skincare brand is asked by Amazon to upload a safety data sheet for a fragrance-free moisturiser. A perfumer's courier refuses a parcel of 50 ml eau de parfum until someone sends "the MSDS".

Do cosmetics need an SDS? For the soap maker the answer is yes, and the supplier should have sent one. For the moisturiser, the law says no and Amazon says "show us". For the perfume, cosmetics law is not the issue at all. The real question is transport. This guide goes through each of those positions and the legal text behind them, so you can tell which rule is in front of you when the request lands.

If you want the history of the term MSDS or a tour of the 16 sections, read MSDS vs SDS: what changed under GHS. If you already know you need one and want to know where to get it, read where to get an SDS for a handmade or small batch product. This article sticks to the narrower question of when an SDS is legally owed.

The legal answer for finished cosmetics in the UK and EU

The duty to supply a safety data sheet sits in Title IV of REACH, in Article 31. It applies to substances and mixtures that meet the criteria for classification as hazardous under CLP, plus a few special categories such as PBT substances and substances on the candidate list. The format is set out in Annex II, which gives the 16 headings you will recognise from any SDS.

Article 2(6)(b) then switches Title IV off for cosmetic products "in the finished state, intended for the final user". The UK version of REACH and the EU text use the same wording. CLP does the same for labelling. Article 1(5)(c) of CLP excludes finished cosmetics intended for the final user, which is why you never see hazard pictograms on a bottle of shampoo.

The reasoning is that cosmetics already have their own safety system. Under the Cosmetics Regulation, every product needs a Cosmetic Product Safety Report signed by a qualified assessor, a Product Information File and a notification before it goes on sale. An SDS is written for someone handling a chemical at work. A CPSR is written for the person using the product on their skin. Lawmakers did not want two overlapping systems for the same jar.

Two details are worth knowing because they come up in real disputes.

"Final user" includes professionals. A salon colourist mixing a professional hair dye is still the final user of a finished cosmetic. The UK trade body CTPA says the exemption covers both home-use and professional-use cosmetics. That does not leave the salon without information. It has its own duties under COSHH, so manufacturers of salon products usually provide safe handling guidance, even though they do not owe a legal SDS.

"Finished state" means finished. If you are a contract manufacturer shipping 200 kg of lotion in an IBC to a brand that fills it, that bulk is not in its finished state for the final user. Treat it as a mixture. If it meets the classification criteria, it needs an SDS.

Where the exemption stops: the raw materials you buy

Back to the soap maker. Lavender oil is not a cosmetic. It is a substance, and like most essential oils it is normally classified as hazardous. Skin sensitisation, aspiration hazard and harm to aquatic life all appear on typical essential oil labels. That puts the supplier squarely inside Article 31. Under the UK text, the SDS must be in English, free of charge, and provided on paper or electronically no later than the date the oil is first supplied.

Some ingredients are not classified, and there the rule is softer. Under Article 31(3), the supplier of an unclassified mixture still has to provide an SDS on request if it contains a hazardous substance above set thresholds (generally 1% by weight, or 0.1% for some categories such as sensitisers and candidate list substances), or a substance with a workplace exposure limit. So ask in writing. A refusal tells you something about the supplier.

There is also a consumer exception in Article 31(4). Hazardous products sold to the general public with enough information to use them safely do not need an SDS unless a downstream user or distributor asks for one. If you buy your oils from a retail site aimed at hobbyists, you may have to request the SDS rather than expect it in the box. As a business user, you are entitled to it.

Why chase these documents if your finished product is exempt? Because your safety assessor works from them. Composition, hazard classes, impurities and physical data from raw material SDS feed the ingredient profiles in Part A of your CPSR. They sit alongside IFRA certificates and allergen statements, which we cover in which safety certificates to request before buying perfumery ingredients. A missing SDS will not always stop an assessment, but it will slow it down and may lead the assessor to make conservative assumptions.

Who is asking you for an SDS, and what to send them

Most SDS requests for finished cosmetics come from businesses, not regulators. The useful question is not "is this legally required?" but "what does this person need to do their job?"

Who is asking	Legal duty to supply an SDS?	What usually works
Amazon dangerous goods review	No. It is a platform requirement.	An exemption sheet for a non-hazardous cream or soap. A full SDS with an accurate Section 14 for perfumes, aerosols and nail products.
Courier, freight forwarder or airline	No SDS law, but the shipper must classify dangerous goods correctly.	An SDS or transport classification showing UN number, class and packing group, or a statement that the product is not dangerous goods.
Retailer or wholesaler	No, for finished cosmetics.	A short product safety information sheet, or a voluntary SDS if their warehouse system requires one.
UK or EU salon or spa client	No, for finished cosmetics.	Safe handling and storage information they can use in their COSHH assessment.
Trading Standards or OPSS	No. They want your Product Information File.	The PIF, including the CPSR. An SDS is not a substitute.
US professional buyer	Possibly, under OSHA HazCom, if the product is hazardous and not packaged for retail sale.	A GHS-format SDS that meets 29 CFR 1910.1200.
Brand buying your bulk product	Yes, if the bulk mixture is classified.	A full SDS for the bulk.

The skincare brand with the moisturiser falls in the first row. Amazon is not claiming the law requires an SDS. It wants evidence that the cream is not dangerous goods. A clear exemption sheet usually clears that. If the listing is still blocked, a short voluntary SDS that says the product is not classified and not regulated for transport usually settles it. Our guide to what gets cosmetic sellers flagged on Amazon, Etsy and Shopify covers the wider listing checks.

Shipping: why your perfume is treated like a chemical

This is where most confusion comes from. Transport rules for road (ADR), air (IATA Dangerous Goods Regulations) and sea (IMDG) do not care whether a product is a cosmetic. They care whether it can catch fire, burst or leak something harmful.

An alcohol-based eau de parfum is typically UN1266, Perfumery products, Class 3 flammable liquid. A deodorant spray or dry shampoo is UN1950, Aerosols, Class 2. Many nail polishes and removers are also flammable liquids. Small consumer packs often qualify for limited quantity rules, which make shipping far easier, but someone still has to classify the product first.

The SDS is the document carriers trust for that classification, which is why our perfumer's courier asked for one. Section 9 gives the flash point and Section 14 gives the transport classification. If those two sections are wrong or missing, the parcel stops. UK government guidance on moving dangerous goods is a sensible starting point for who is responsible for what.

The US position is narrower

If you sell into the US, do not assume the UK and EU exemption travels with you. OSHA's Hazard Communication Standard, 29 CFR 1910.1200 exempts, in paragraph (b)(6)(viii), "cosmetics which are packaged for sale to consumers in a retail establishment", along with cosmetics brought in by employees for their own use.

A lipstick on a shop shelf is exempt. A salon-only keratin smoothing treatment in a litre back-bar bottle may not be. If that product contains hazardous chemicals, the manufacturer or importer is expected to classify it and supply an SDS to the salon, which is an employer under OSHA. FDA cosmetics law, including MoCRA, does not add an SDS duty of its own. It has its own listing and safety substantiation rules, covered in our MoCRA product listing and registration guide.

UFI codes and poison centres

Brands who also make home fragrance often ask whether cosmetics need a UFI. They do not. In the EU, the poison centre notification and UFI duties come from CLP Article 45 and Annex VIII, and CLP does not apply to finished cosmetics. Poison centres get cosmetic formulation data through the cosmetic notification instead. In the UK, Article 13 of the UK Cosmetics Regulation requires notified information to be made available to UK poison centres.

A classified candle or reed diffuser sold in the EU is a different matter. It is a CLP mixture, so it needs a CLP label, an SDS for business customers and, if hazardous, a PCN and a UFI on the label. In Great Britain there is no obligation to generate a UFI. Submitting SDS information to the National Poisons Information Service is currently voluntary, as explained in the government guidance on NPIS submissions.

Products that look like cosmetics but are not

The exemption follows the legal definition of a cosmetic: something applied to the external parts of the body, teeth or mouth mainly to clean, perfume, protect or change appearance. Anything outside that definition is not exempt.

Candles, wax melts, reed diffusers, room sprays and car fresheners are chemical mixtures under CLP, and their fragrance load often makes them classified. They need the CLP treatment described above and usually a toxicological risk assessment rather than a CPSR. Hand sanitisers are normally regulated as biocides in the UK and EU, not cosmetics, so do not rely on the cosmetics exemption for them either. Borderline products, such as massage candles that turn into oil, get their own analysis. Our TRA vs CPSR guide explains how to tell which side of the line you are on.

If you write a voluntary SDS for a cosmetic

A voluntary SDS is fine, and often the quickest way through a marketplace or warehouse review. Just make sure it describes the product honestly as a cosmetic:

• Section 1 should identify the product as a cosmetic and give its intended use.
• Section 2 can state that the product is not subject to CLP classification as a finished cosmetic. Do not copy pictograms from the raw material SDS.
• Section 9 needs a real flash point for anything containing alcohol or volatile solvents.
• Section 14 must match how you actually ship the product.
• Section 15 should cite the Cosmetics Regulation and the REACH and CLP exemptions.

Do not put CLP hazard labels on the retail pack because the voluntary SDS exists. The label rules for a cosmetic still come from the Cosmetics Regulation.

A quick way to decide

When the next request arrives, ask three questions in order. Is this product a finished cosmetic for the final user? If not, the normal SDS rules apply. If it is, is the request about transport? If so, classify the product for shipping and provide the data. If it is neither, the person asking has a commercial reason. Find out what they need to see, and send the lightest accurate document that meets it.

The soap maker, by the way, should go back to the lavender oil supplier and ask for the SDS in writing. That one is owed.

Related reading on the Phoenix blog

• MSDS vs SDS: what changed under GHS and what UK sellers need now
• Where to get an SDS for a handmade or small batch product
• TRA vs CPSR: which safety assessment does your product need?
• Toxicological risk assessment for candles and wax melts
• What is a CPSR? The complete UK and EU guide

Myths we hear

• If Amazon asks for an SDS, the law must require one. Amazon asks so it can decide how to store and ship your product. It is a platform rule, and an exemption sheet or a voluntary SDS normally satisfies it.
• The cosmetics exemption covers everything in my unit. It covers finished cosmetics for the final user. Raw materials, bulk you sell to another brand, and home fragrance products are not covered.
• A salon is a business, so it needs an SDS for every product. UK and EU law treats professional users of finished cosmetics as final users. The salon still has COSHH duties, so give it safe handling information.
• If my product has no SDS, it cannot be shipped by air. It can, if it is not dangerous goods, or if it is packed and declared correctly. The SDS just makes the carrier's classification job easier.
• An SDS proves my cosmetic is safe. It does not. An SDS describes chemical hazards for handling. Consumer safety is proven by the CPSR.

What to do this week

1. Write down every product you sell and mark which are finished cosmetics, which are bulk or semi-finished, and which are not cosmetics at all.
2. Check you hold a current SDS for every raw material, and ask suppliers for any that are missing or more than a few years old.
3. For alcohol perfumes, aerosols and nail products, get a flash point or transport classification so Section 14 of any SDS is accurate.
4. Prepare a one-page exemption statement for non-hazardous cosmetics, citing REACH Article 2(6)(b) and CLP Article 1(5)(c).
5. Commission a voluntary SDS only where Amazon, a carrier or a business customer actually needs one.
6. If you sell professional products in the US, check whether they are packaged for retail sale and whether any are hazardous under HazCom.

Frequently asked questions

Official sources and legislation

• UK REACH Article 2: scope and exemptions (legislation.gov.uk)
• UK REACH Article 31: requirements for safety data sheets (legislation.gov.uk)
• UK REACH Annex II: compilation of safety data sheets (legislation.gov.uk)
• EU REACH Regulation (EC) No 1907/2006 (EUR-Lex)
• GB CLP Article 1: scope (legislation.gov.uk)
• EU CLP Regulation (EC) No 1272/2008 (EUR-Lex)
• Regulation (EC) No 1223/2009 on cosmetic products, UK version (legislation.gov.uk)
• HSE guidance on safety data sheets
• HSE COSHH guidance
• OSHA Hazard Communication Standard, 29 CFR 1910.1200 (eCFR)
• GOV.UK: submitting chemicals information to the National Poisons Information Service
• GOV.UK: moving dangerous goods
• CTPA: Safety Data Sheets (SDS) and cosmetic products