Frequently asked questions and answers in chemical safety

MSDS-Europe – Frequently asked questions and answers in chemical safety

Collection of questions and answers in the field of chemical safety. Do you have questions related to chemical safety? Ask the expert!

Questions related to chemical safety

• What is the UFI? Do I have to do anything with it as a distributor?
• I would like to have a safety data sheet and label for cosmetics. What information do I need to provide? Do the requirements of chemical safety also apply to this product group?
• What is the purpose of a safety data sheet?
• Do all chemical products require a safety data sheet?
• Do I always have to have a safety data sheet in the language of the target country, or can I use the safety data sheet in a foreign language (e.g. English) provided by the supplier?
• How can I check if the safety data sheet provided by the supplier is correct?
• How long a safety data sheet is valid and how often should it be updated?
• Who can create a safety data sheet?
• Is it enough if I download the safety data sheet from the internet?
• In our company English language is a must, thus the safety data sheets are not translated to the national language of the country, since everyone can read them. Is this in compliance with the regulations?
• How can I determine which of my distributed products are subject to PCN notification and which are not?
• What kind of data do I need for the PCN notification?
• I have already created the UFI codes for my products using the online UFI generator and these are also printed on the product labels. Does this mean that I have fulfilled my PCN notification obligations?
• At the request of our customers, we have made a PCN notification for our product which is not classified as hazardous. Does the generated UFI code need to be included on the label?
• We import mixtures classified as hazardous to health under CLP from China as raw materials, which we use in the manufacture of our own products, which are also classified as hazardous under CLP. We have already made PCN notifications to the designated authorities in the countries where our products are marketed. Do we have any further notification obligations?

Questions related to our services

• I would like to order the creation of a safety data sheet, but I do not know what kind of quote I should request. How can I decide among the services?
• What does the compilation of the safety data sheet mean, what kind of documents are needed?
• What does the translation with adaptation mean?
• What is a safety data sheet revision?
• What does the creation of label draft mean, what kind of documents are needed?
• What kind of priority services are available?

Questions related to the order and delivery process

• How can I request a quote?
• When requesting a quote, what kind of information do I need to provide in the e-mail?
• Is there any discount for ordering several data sheets?
• In what format should I send the source document?
• How will the finished safety data sheet look like?
• Is it possible to include my own company logo in the safety data sheet?
• How long is the ToxInfo quotation valid?
• What should I do if I want to order a safety data sheet service?
• How can I know if the source documents attached to the order form are appropriate?
• Do I have to fill out a new order form for each order?
• How many safety data sheets can I order at once?
• How long will my order take?
• Will I always receive my order on the day indicated in the confirmation?
• Is there any kind of guarantee for the completed data sheet?
• Do I have to pay in advance?
• If I paid against a proforma invoice, will I still receive a final invoice?

Questions related to chemical safety

What is the UFI? Do I have to do anything with it as a distributor?

The unique formula identifier (UFI) is a 16-character code to be indicated on the label of hazardous mixtures.

The UFI is also an element in the notification process of hazardous mixtures towards poison centres carried out in a unified, harmonised form (PCN).

The PCN notification including the UFI code has to be done by those who place the product on the market in the country.

Resellers are not obliged to notification.

If the label of the product is damaged or if the manufacturer changes the composition of the product in such way that a new UFI code has to be generated, then the product label needs to be replaced or updated. In these cases, the reseller may have obligations.

You can read a summary about the distributors’ other tasks here.

I would like to have a safety data sheet and label for cosmetics. What information do I need to provide? Do the requirements of chemical safety also apply to this product group?

It is not required to create a safety data sheet for cosmetic products and to make them available for customers. Cosmetic products are not subject to the provisions of chemical safety regulations.

However, the safety data sheet may be recommended and appropriate in certain cases.

On the other hand, for placing cosmetic products on market, the label made in accordance with the 1223/2009/EC regulation is definitely important.

What is the purpose of a safety data sheet?

Safety data sheets are important communication tools in the supplier chain, helping each participant in fulfilling their obligations relating to the management of risks arising from the use of substances and mixtures.

You can find more information on the importance of the safety data sheet here.

Do all chemical products require a safety data sheet?

The REACH regulation clearly defines the products for which a safety data sheet is obligatory and the cases where a safety data sheet must be made available on request.

Of course, if certain well-defined conditions are met, the safety data sheet does not have to be prepared and provided to the customers.

The requirements for the rules on providing the safety data sheet can be found here.

Do I always have to have a safety data sheet in the language of the target country, or can I use the safety data sheet in a foreign language (e.g. English) provided by the supplier?

Activities involving dangerous substances or mixtures in EU countries require a safety data sheet in the language of the target country, unless the member country decides otherwise.

In the case of products which do not require compiling  and making available safety data sheets but the supplier provide them in English (or in other foreign language), then they can be used as an information source for taking safety measures.

If you buy chemical products for your own industrial use (also as a downstream user), you have to have the safety data sheet in the target language, but it is not necessary to change the language of the label (the product is not placed on the market and the information provided to the workers is based on the SDS).

How can I check if the safety data sheet provided by the supplier is correct?

As a reselling distributor, regarding the safety data sheets, it is not your responsibility to check the content of the documents received. However, you should at least check the form of the provided safety data sheet. Regarding the product labelling, you should check the followings:

• the content of the product label is consistent with the safety data sheet
• it has been prepared in accordance with the current CLP regulation

If you are a distributor obliged to notification (your company is the first distributor in the target country), then you are also responsible for the content of the safety data sheet. In this case, it your task to prepare the safety data sheet in the target language and you have to submit the notification as well.

As an importer, you have similar responsibilities regarding the safety data sheet and the labelling as above (there are other additional tasks).

As a downstream user, you also have to check the documents because the contained information is necessary for creating safe working conditions. As a mixture-preparing downstream user, you have to create  your own products’ SDS based on the safety data sheets of the raw materials.

When purchasing a product, try to choose a reliable supplier who can guarantee that the information in the original safety data sheet is accurate and in compliance with the regulations.

How long a safety data sheet is valid and how often should it be updated?

Safety data sheets do not have “validity” or “expiry” date!

The validity period of safety data sheets is not determined by the date of issue or revision. The validity (adequacy) of a safety data sheet depends on its compliance with the applicable regulations and legislation.

The revision and update of safety data sheets may be necessary when there is a new, essential information about the product or there are changes in the requirements of content/form laid down in regulations.

Who can create a safety data sheet?

For the creation or “translation” of safety data sheet, having a special qualification or other requirement is not necessary.

Any “competent person” can create a safety data sheet if he/she also accepts the responsibility for the non-negligible consequences regarding its compliance.

The safety data sheet is the number one “information carrier” of the chemical products in the supplier chain. Read more about the “functional” importance of the safety data sheet here.

We would like to emphasise that the label, which contains information for the consumers about the dangers, appropriate usage and basic instructions on elimination, can only be prepared based on a correct safety data sheet.

The safety data sheet translation is also the result of a complex, professional process and it is not always done properly, even when using special safety data sheet authoring software created by “experts”.

Click here for a sample data sheet prepared in accordance with the current formal and content requirements.

Is it enough if I download the safety data sheet from the internet?

Recently, it has become a “common” practice that companies “publish” the safety data sheets on their website, making them available for everyone. However, this practice is not appropriate for several reasons.

A company can only fully comply with the obligation to transfer a safety data sheet as set out in the relevant legislation if it “actively” transfers the data sheet and can provide some form of proof of this in the future.

The fact that you can download from the website does not constitute as “handing over” the safety data sheet.

In our company English language is a must, thus the safety data sheets are not translated to the national language of the country, since everyone can read them. Is this in compliance with the regulations?

The safety data sheet must be provided in the language of the target country. Even if the colleagues can read it in English, in case of an accident or other hazardous situations it is not certain that the person involved in the assistance will be able to speak the language

The above possibility was taken into account by the legislators when they laid down clear rules on the language in which the safety data sheet should be made available to the user of the substance/mixture.

Even for your own industrial use, it is necessary to prepare a safety data sheet in the target language and make it available to the workers at the work site (a “hidden” data sheet in the office is not appropriate). In case of industrial use, however, it is not necessary to relabel the product in the target language if the original language is clearly indicated on the packaging.

How can I determine which of my distributed products are subject to PCN notification and which are not?

• First of all, you should define your role in the supplier chain. The distributor and importer responsible for the first placing on the market have a “default” obligation to notify.  As a reselling distributor, the company only has a PCN notification obligation if the supplier who is obliged to notify has not done so. It also follows that, as a reseller, you need to make sure that the product has a PCN notification in the Member State where it is sold.
• If the product is classified based on its effects on health or physical hazards (in other words, it is hazardous) in accordance with CLP, the mixture has to be notified.
• Determine when your notification obligations may arise.
• Distinguish the products based on their usage: consumer, professional or industrial use. From the 1st of January 2021, mixtures intended for consumer and professional uses have to be notified. From the 1st of January 2024: products for industrial use. From the 1st of 2025: end of grace period for mixtures already on the market.
• Examining certain special product categories exempted from notification and CLP regulation.

Read further information on the notification obligation here

What kind of data do I need for the PCN notification?

You need the following information for the notification:

• Name and contact details of the contact person (who will be able to respond to any enquiries from the authorities at short notice)
• Trade name of the product
• UFI code
• Type of use (industrial, professional or consumer)
• Type of notification (for the first product notification choose Initial submission)
• Product type, in accordance with EuPCS category
• Country of the notification (where the product is placed on the market and used)
• Language of the notification
• Product packaging (packaging material, package size)
• The exact composition of the hazardous mixture and the concentration of the ingredients in the mixture (preferably the ingredients should add up to 100%). It is usually not enough to give the ingredients indicated in the safety data sheet!
• CLP classification of all ingredients
• CLP classification of the mixture + relevant hazard statements
• Label elements of the mixture
• Safety data sheet of the mixture (only mandatory to be uploaded in certain cases)
• Toxicological data for the mixture (based on Section 11 of the SDS)
• pH value of the mixture (if not relevant, give the reason why)
• Colour, state of the mixture (based on Section 9 of the SDS)

I have already created the UFI codes for my products using the online UFI generator and these are also printed on the product labels. Does this mean that I have fulfilled my PCN notification obligations?

The existence of the UFI code alone is not sufficient, “blank” UFI codes without PCN notification cannot be included on the label. Therefore, after the UFI code has been generated, the PCN notification must be made and only then should the UFI code be applied to the label.

At the request of our customers, we have made a PCN notification for our product which is not classified as hazardous. Does the generated UFI code need to be included on the label?

If you choose to make a voluntary PCN notification for your non-hazardous product, it is not mandatory (only optional) to indicate the UFI code on the label.

We import mixtures classified as hazardous to health under CLP from China as raw materials, which we use in the manufacture of our own products, which are also classified as hazardous under CLP. We have already made PCN notifications to the designated authorities in the countries where our products are marketed. Do we have any further notification obligations?

Yes, you have additional notification obligations. As an importer, you also have to make a PCN notification for the imported hazardous product in the country where you manufacture your own product, as importing is also considered a kind of “placing on the market” under the relevant regulation.

Questions related to our services

I would like to order the creation of a safety data sheet, but I do not know what kind of quote I should request. How can I decide among the services?

The first step is to check what kind of document(s) you possess.

If you have received a data sheet in a foreign language, then you need a translation with adaptation.

If you have a data sheet in the target language but you are not sure if it complies with the relevant regulations then you can order the revision of the safety data sheet.

If you have a new chemical product or if you have not received safety data sheet from the seller, you need to order the compilation of a safety data sheet. In this case, you have to provide the data and information set out in service description.

Of course, our Customer Service will also help you finding the right service.

What does the compilation of the safety data sheet mean, what kind of documents are needed?

The compilation of a safety data sheet is a complex, multi-step process where we prepare a safety data sheet based on the available data and in accordance with the relevant requirements. This service is mainly used by manufacturers (or downstream users who prepare mixtures) and distributors responsible for placing the product on the market as first ones, if the safety data sheet is not available in the target language.

For the compilation we need the trade name of the product, a precise description of its composition and other known information about the product and its ingredients. The full list of required documents will be specified at the time of ordering.

What does the translation with adaptation mean?

If the supplier can only provide a safety data sheet in a foreign language, then it needs to be translated. When translating the safety data sheet, it is important to avoid loan translation because in this case much information would be transferred into the target language data sheet which is only relevant in the country of the original document and of course, will not comply with the legislations of the target country. Furthermore, the content and form of the safety data sheet is such that some parts of the wording are legally binding and must be used in the form prescribed by the regulation (e.g. name of the sections, hazard and  precautionary statements, etc.)

The translation with adaptation means that the data sheet is not just translated but we also make sure that the appropriate terminology is used and that the relevant parts are adapted (localised) in accordance with legislation in force of the target country and the EU.

What is a safety data sheet revision?

The safety data sheet may need to be revised in many cases.

The most important case is when there are changes in the requirements of content/form laid down in regulations.

Another common reason is when a new safety data sheet is available in a foreign language, and there are changes that require the translated version of the sheet to be updated.

Furthermore, there may be significant changes in the composition of the product or there are new information available regarding the product hazards which affect the classification and the related risk management measures.

As a result of the safety data sheet revision service, we provide an SDS to our clients which is in compliance with all relevant legislation in force at the time of creation.

What does the creation of label draft mean, what kind of documents are needed?

If you distribute a hazardous substance or mixture, it is necessary that the product is labelled in accordance with the legislation in force. Based on the safety data sheet provided, we will determine the  mandatory label elements required for the product from a chemical safety point of view and provide this in an editable Word format.

What kind of priority services are available?

If you need a safety data sheet urgently for any reason, we have two types of priority services to choose from.

In case of Rapid service, we can prepare the requested safety data sheets within 3 working days. This service is available when ordering a maximum of 3 data sheets.

In case of Express service (1 working day), we will prepare the requested safety data sheet for no later than the end of the next working day. This service is available when ordering a maximum of 1 data sheet.

When requesting a priority service, please always take the weekends and public holidays into account which may delay the delivery date. For more information on the applicable prices, please refer to the order form.

In case of saturated capacity, we may not be able to provide a Rapid or Express service. If that is the case, we will let you know before sending the confirmation.

Please contact our Customer Service by phone for quicker administration.

Questions related to the order and delivery process

How can I request a quote?

We suggest requesting a quote for a safety data sheet creation by filling out the online form on our website.

To request a quote directly by e-mail, please use the e-mail address found under the Customer Service menu. Quote requests will be processed and replied to within 24 hours. In cases of extreme urgency (when ordering Rapid or Express service), we recommend contacting our Customer Service by telephone.

When requesting a quote, what kind of information do I need to provide in the e-mail?

Please describe exactly what kind of service you need and how many products you would like to use the service for. If you need a translation or a revision of an outdated data sheet and the documentation to be translated/revised is already available, please attach the document(s) to the quote to speed up the process.

Is there any discount for ordering several data sheets?

We offer a significant quantity-based discount for ordering several data sheets at once. The discount rate will be explained in the quote.

The quantity discount is only valid for translations ordered for the same target language.

In what format should I send the source document?

For the working process, we prefer using Word or non-secured PDF files.

How will the finished safety data sheet look like?

We deliver our safety data sheets to our customers with a uniform look.

If your company policy requires different image/colours, we can prepare and deliver the safety data sheet according to your request after prior consultation.

Is it possible to include my own company logo in the safety data sheet?

Of course, you can request the safety data sheet with your own company logo but please, do not forget to fill out the relevant parts in the order form and send the logo together with the order in a JPEG format and appropriate resolution.

How long is the ToxInfo quotation valid?

Every quote by ToxInfo contains the validity date as well.

After the validity date, our company sends an updated quote with a new reference number, typically with the same price but with a different delivery date.

What should I do if I want to order a safety data sheet service?

We send you the order form as an attachment to the quote. You have to send back the filled and signed order form as well as the documents and information indicated in the quote.

We also accept your own order form, standardised by your company, but in this case, we ask you to include all the information that is indicated in our order form, as we will need it to create the safety data sheet.

How can I know if the source documents attached to the order form are appropriate?

Before confirming the order, we always check the received document. In 90% of the cases, we can already see at this stage if there is something wrong with the basic documentation, so we can indicate that we need additional information before confirming the order.

In rare cases, it may only be revealed after confirmation, during the expert background/preparatory work, that a document is not correct. In this case, depending on the depth of the problem, the contact person or the expert directly contacts the client and tries to clarify the issues raised. In this case, the delivery date may be extended compared to the deadline indicated in the confirmation.

Do I have to fill out a new order form for each order?

The previously filled order form cannot be used for new orders since it contains questions specially related to the given product/products (e.g. trade name, usage etc.).

How many safety data sheets can I order at once?

There is no upper limit for the quantity that can be ordered at once. Our prices are quantity based; we can give you discount based on the number of data sheets.

For larger quantities you can order at a better price, or we recommend to join the MSDS-Europe Customer Support Program.

How long will my order take?

Our normal delivery date is 8-10 working days from the day of order but you can also choose Rapid or Express service in the order form.

The document sent with the confirmation contains the delivery date.

We deliver the order on the day indicated in the confirmation, at the end of the working day the latest.

Will I always receive my order on the day indicated in the confirmation?

No. We deliver the order after receiving the receipt of the proforma invoice. You will be notified on the day when the order is completed and, where applicable, asked to check that the transfer has been made.

Our contractual clients have the option for payment against final invoice. Please contact our customer service for information on our contract arrangements.

Please refer to the reference number of the order for easier identification when transferring!

Is there any kind of guarantee for the completed data sheet?

Our company offers a full professional and financial guarantee for the safety data sheets we prepare. Our financial guarantee covers all direct and indirect damages. Our customer service will respond to any comments within 24 hours.

Do I have to pay in advance?

Yes, but not in every case.

Our company policy prefers payment against pro forma invoice. The deadline for the payment of the pro forma invoice sent with the confirmation is the delivery date of the order.

Our contractual clients can pay against final invoice.

If I paid against a proforma invoice, will I still receive a final invoice?

In any case, we will send you a copy of the final invoice for VAT purposes electronically after the payment against pro forma invoice and after the service has been provided.

If you wish to receive the invoice by post, please let us know explicitly.

Can’t find the answer for your question?

Ask your question related to chemical safety by filling out the form below.