Safety data sheets simplified: can a single SDS serve all markets?

As Safety Data Sheet (SDS) authoring consultants, one of the most common questions we hear is: “Can we create a single SDS that works globally?” It’s an appealing idea – streamlining documentation, cutting costs, and simplifying compliance – however, the patchwork of regulatory requirements across jurisdictions makes a truly universal SDS nearly impossible.

In this article we unpack why global harmonisation remains elusive, highlight key differences between regional SDS expectations, and explore where strategic overlaps can be leveraged to reduce duplication and improve efficiency.

Region-specific templates

The most important point to understand is that each country or region has its own chemical regulations and restrictions. In this article, we’ll focus on the chemical and health-related aspects.

Although the United Nations introduced the Globally Harmonized System (GHS) to standardize hazard communication, its implementation varies significantly by country. GHS provides a framework – including a 16-section SDS format – but each country may adopt or interpret different versions of GHS, and even within the same version, they may enforce unique requirements. This leads to differences not only in classification criteria but also in formatting, language, and mandatory content. These discrepancies make it impossible to create a single SDS that complies with every country’s rules.

The table below illustrates how two major markets – the United States and China – differ in their GHS adoption and SDS section expectations:

Region-specific requirements impacting SDS content

Beyond general formatting and hazard communication rules, some regions impose local regulatory obligations that directly affect what must be included in an SDS. Two common examples are Poison Centre Notifications and REACH registration numbers:

• In the European Union, hazardous products must be notified to a poison centre and assigned a UFI (Unique Formula Identifier). This UFI must be included on the SDS – but it's only relevant and legally required within Europe. Learn more here. 
• It is essential to include a poison centre telephone number on the SDS that is specific to the region in which the product is being marketed. These requirements differ across countries. For instance, Ireland may require only a single poison centre number, while Italy mandates ten. In Great Britain, both the Unique Formula Identifier (UFI) and the poison centre number are optional. These variations underscore the importance of preparing region-specific SDS.
• REACH registration numbers are often included in SDS. These are identifiers assigned to substances registered under specific REACH frameworks – such as EU REACH, UK REACH, or Korea REACH. Each jurisdiction issues its own registration number, which is only valid within that region. Including a REACH number from one jurisdiction in an SDS intended for another can lead to compliance issues or misinterpretation.

Regional differences in classification systems

Another key challenge is that regions use different classification systems and chemical inventories.

Examples:

• Europe has mandatory classifications set under CLP which are managed by ECHA (European Chemicals Agency).
• China uses the GB 30000 series and the Catalogue of Hazardous Chemicals.
• Japan bases its classifications on test data reviewed by NITE (National Institute of Technology and Evaluation).

Due to variations in the hazard criteria and classification logic between each country’s implementation of GHS, a chemical may be classified differently in each country. These discrepancies impact:

• Labelling requirements
• Risk and safety phrases
• Precautionary measures

Even if the substance is the same, its SDS must be adapted to reflect regional classification.

Regional compliance in the EU: OELs and regulatory information differences 

Even within the EU, where a shared regulatory framework for SDS exists, national differences still apply, particularly when it comes to Occupational Exposure Limits (OELs) and Section 15 regulatory disclosures.

OELs, which define the maximum allowable airborne concentration of a hazardous substance in the workplace, are established by national authorities. This means:

• Each EU Member State can maintain its own set of OELs.
• These must be reflected in Section 8 of the SDS, based on the country where the product is placed on the market.

In Section 15, further national-specific requirements may apply. For example:

• Germany enforces TRGS 220, which mandates the inclusion of specific references and standardized phrases.
• A WGK (Water Hazard Class) classification is also required in Germany – something not applicable in countries like France, Spain, or Poland.

As a result, even when the hazard classification remains consistent across the EU, the SDS may need to be adapted for each Member State to reflect local regulatory obligations. This often means producing multiple SDS versions to ensure full compliance.

Regional exceptions: shared SDS agreements

Despite all these complexities, there are a few regions where combined SDS may be possible:

While some regions allow shared SDS there are limited exceptions. Even in these cases, local adaptations are often required.

There are also examples where shared SDS were once allowed but are no longer accepted. For instance, until 2018 it was acceptable to use a U.S. SDS for Mexico, but Mexico has since introduced its own SDS requirements. As the number of countries officially adopting GHS is growing so are the number of divergences in implementation.

Emergency contact requirements

Most countries require a 24/7 local emergency response number to be listed on the SDS – often staffed in the local language. Examples include:

• The EU, under CLP Article 31, requires emergency contact details on the SDS.
• China mandates a Chinese-language emergency number.
• New Zealand requires a freephone 24/7 emergency contact, reachable from within the country.

Many clients are unaware of these requirements until a product is flagged by a regulatory authority.

Learn more about Ricardo’s Emergency Response Service >

GHS offers a valuable foundation, but regional divergence in classification, structure, and legal obligations means SDS must be tailored to each market. Attempting to combine multiple jurisdictions into one document risks confusion and non-compliance.

That’s why expert SDS authoring and regulatory support is essential for companies operating across borders.

How can Ricardo help?

At Ricardo, our Chemical Risk team offer end-to-end support to help companies remain compliant with the SDS Regulations globally, including national variations.

Find out more here >