SDS requirements in the EU and under US OSHA HazCom share the same 16-section layout, but they differ on language, legal content and who must supply the sheet. An Indian supplier's generic SDS rarely meets either market's rules unchanged.
In the EU the sheet must follow Annex II of REACH, as amended, and be written in an official language of the country where the product is placed on the market. In the US, OSHA's Hazard Communication Standard (29 CFR 1910.1200) requires English and puts the duty on the manufacturer or importer to prepare it.
What does the EU require in a safety data sheet?
The EU sheet is a legal document tied to REACH and CLP. For a hazardous substance or mixture, the supplier must provide it free of charge, on paper or electronically, at or before the first delivery. Points that often fail on imported goods:
- The REACH registration number must appear in sections 1 and 3 once the substance is registered.
- Classification must follow the CLP Regulation, not just a generic GHS table.
- A 24-hour emergency telephone number must reach someone who can respond in the relevant language.
- Substances registered at 10 tonnes a year or more and classified as hazardous need exposure scenarios attached, forming an extended SDS.
- The sheet must carry a revision date and a note of what changed in the latest version.
What does OSHA HazCom require?
OSHA's rule is aligned with an earlier revision of the Globally Harmonized System. It also uses 16 sections in the same order, but OSHA does not enforce sections 12 to 15 (ecological information, disposal, transport and regulatory information), because other agencies cover those topics. Chemical manufacturers and importers must still provide the sheet with the first shipment and again when it is updated.
OSHA has proposed aligning with a newer GHS revision. Check OSHA's current rule text before you finalise label or sheet templates, because the transition dates are the part that moves.
Where the two systems differ in practice
- Language: the EU needs the local language of each member state, while the US needs English.
- Identifiers: the EU wants EC numbers and registration numbers, and the US wants CAS numbers and a manufacturer or importer address.
- Classification: a substance can carry different hazard classes in the two systems, so the sheet should not be copied across without checking.
- Scope of content: sections 12 to 15 are mandatory in the EU, and effectively optional under HazCom.
- Length of use: US employers must keep sheets accessible to workers, and EU suppliers must update them when new hazard information appears.
Making your Indian supplier's SDS usable
Ask the factory for the SDS before the first sample ships, not after the order. Compare the CAS number, classification and transport data with the TDS and the label. If the transport section shows a UN number but the packaging and booking say non-dangerous, stop and resolve it. Our guides on the 16 sections of an SDS and who must provide an SDS explain each field, and GHS labels should match what the sheet says.
Many importers hire a local regulatory author to convert the sheet into the local format and language. That is normal and worth planning for, because the legal responsibility for a market-ready sheet usually sits with the importer or its representative.
How we help
We check the supplier's SDS, label and certificate of analysis against each other, and flag mismatches before goods ship. To have your own documents reviewed before the first order, book a free sourcing review.