Seven Common SDS Compliance Issues (And How to Fix Them)

July 27, 2026 by Fiona Moir

Most organisations do not discover their SDS errors until an audit, an incident, or a regulatory inspection. Here is what to look for and what to do about it.

A Safety Data Sheet is a legal document. It is also one of the most frequently non-compliant documents in a manufacturer's compliance portfolio. Across jurisdictions from the EU and UK to the US, Korea, Brazil, and beyond, regulatory authorities have identified SDS quality as a persistent problem, and enforcement activity is increasing.

For EHS and regulatory managers, the stakes are clear. An inaccurate or outdated SDS can result in regulatory fines, failed audits, product holds at the border, downstream liability, and, in the most serious cases, result in regulatory fines, failed audits, supply chain disruption, downstream liability and, in some cases, compromise the information relied upon by workers and emergency responders. 

What makes SDS compliance genuinely difficult is the moving target. GHS revision cycles, jurisdiction-specific deviations, substance-level regulatory changes, and ongoing updates to classification criteria mean that an SDS that was fully compliant eighteen months ago may not be compliant today.

This article sets out the seven most common non-compliance issues our consultants find when reviewing SDS portfolios, and what organisations should do to address them.

Classification is out of date

Classification underpins the entire SDS. If it is wrong, every hazard statement, precautionary statement, label element, and transport classification derived from it is potentially wrong too.

The most frequent cause is that classification was set at product launch and never revisited. Regulatory lists change. SVHC designations are added. Harmonised classifications under CLP Regulation Annex VI are updated. New toxicological data becomes available. Under OSHA HazCom 2024, manufacturers are now required to update SDS within six months of becoming aware of new significant information that changes the hazard classification.

The fix: Establish a classification review trigger. Any time a component substance appears on a regulatory update notification, the classification for all products containing it should be queued for review. This is a process and system problem as much as a chemistry problem.

Jurisdiction-specific requirements are missed

GHS is a globally harmonised system. That word "harmonised" does more work than it should. In practice, each adopting country implements GHS with variations: different revision levels, additional local requirements, and country-specific section content.

Common gaps include missing country-specific emergency contact numbers, incorrect or absent national poison control information, local language requirements not met, and Section 15 (Regulatory Information) that reflects only the home market and ignores export markets.

A US SDS prepared under HazCom 2024 (GHS Rev. 7) will not satisfy EU CLP requirements, and vice versa. A document authored for the EU will need adaptation for Korea (K-REACH), Japan (CSCL), Australia (HSIS), and others.

The fix: Treat each market as a distinct authoring task with its own compliance checklist. A single "global" SDS is not a viable compliance strategy.

Section 1 contact details are incorrect or insufficient

This is one of the most audited sections and one of the most frequently wrong. Regulators in the EU, UK, and US have all flagged missing or incorrect emergency telephone numbers as a common deficiency.

In addition, many jurisdictions require a legal entity importer to be listed on the SDS within section 1.3. Frequently, this is not addressed in the SDS  and is picked up regularly by enforcement bodies.

Emergency telephone number requirements differ between jurisdictions and may include national poison centre details or access to specialist toxicological advice depending on the market.  Under OSHA HazCom, the number must be operational during normal business hours at minimum, with 24-hour coverage for substances presenting immediate hazards. These are not the same requirements.

We regularly see SDS documents where the emergency number is a general company switchboard, a number that has since changed, or a number for a different country.

The fix: Verify emergency contact information against current regulatory requirements for each jurisdiction. If 24-hour toxicological advice cover is required and you do not have it, engage a specialist provider.

Exposure limits are outdated or missing

Section 8 (Exposure Controls/Personal Protection) must reflect the occupational exposure limits (OELs) applicable in the country of use. These are updated regularly. OSHA PELs, UK WELs, EU OELVs, and national transpositions of the EU Chemical Agents Directive are all subject to revision on different cycles.

We frequently find SDS documents where OELs reflect values that have since been tightened, where values from one jurisdiction are presented for another, or where Section 8 is simply incomplete for substances that do have established limits.

The fix: Include OEL review as part of your annual SDS maintenance cycle. Flag any substance where the applicable limit has changed since the last SDS version.

Transport classification conflicts with Section 14

Section 14 covers transport hazards under UN model regulations, as implemented by IMDG (sea), IATA-DGR (air), ADR/RID (road/rail in Europe), and equivalent regimes elsewhere. These are not the same as GHS hazard classification, and the two systems need to be separately maintained.

We see organisations where the GHS classification has been updated following a regulatory change but the transport classification in Section 14 has not been reviewed. We also see Section 14 populated with UN number assignments that have not been validated against the current Dangerous Goods List.

The fix: Treat transport classification as a separate workstream with its own review triggers, aligned to each annual update cycle for the relevant transport regulations.

Mixture SDS relies on undisclosed or stale component data

For mixtures, the SDS is only as good as the data on the components. A common weakness is over-reliance on supplier-provided SDS information that has not been independently verified, particularly for complex mixtures where multiple supplier documents are the source.

Confidential Business Information (CBI) claims present a further complication. Where component identity is protected, the SDS must still disclose sufficient information to enable safe handling and emergency response. Getting this balance right requires genuine regulatory expertise.

The fix: Audit the upstream data behind your mixture SDS. Identify where you are relying on supplier documents that have not been reviewed for currency or accuracy. Consider whether CBI claims are proportionate and defensible.

No version control or change management process

This is a process failure rather than a content failure, but it has direct compliance consequences. Regulatory authorities expect to be able to trace SDS history. In the event of an incident, an outdated SDS in circulation with no evidence of when it was superseded is a significant liability.

We find organisations operating without a documented SDS review cycle, without version numbering, and without a process for withdrawing superseded documents from circulation with customers and distributors.

The fix: Implement an SDS management system with version control, distribution tracking, and a documented review and update procedure. The frequency of review should be set against the regulatory risk profile of your portfolio.

What this means in practice

None of these issues is unusual. We see all seven of them regularly across portfolios of every size, in organisations with experienced EHS teams. The common thread is that SDS compliance is treated as a documentation task rather than a regulatory risk management process.

The organisations that manage it well have three things in place: clear ownership, a defined review cadence, and access to regulatory expertise that keeps pace with changes across the jurisdictions where they sell.

If you are not certain that your current SDS portfolio reflects current regulatory requirements across your markets, the honest answer is that it almost certainly does not, at least not fully.

How exposed is your SDS portfolio?

Our HazCom consultants offer a free discovery call to help you understand where your greatest areas of risk and non-compliance are likely to sit, and what a structured review programme would look like for your portfolio.

No obligation. No sales pitch. A direct conversation with a specialist who works on SDS compliance every day.

FAQs

• What is a Safety Data Sheet (SDS)?

  A Safety Data Sheet is a standardised legal document that provides detailed information about a chemical substance or mixture. It covers hazard identification, composition, safe handling, storage, emergency response, disposal, and transport requirements. SDS documents are required by law for hazardous chemicals placed on the market in most jurisdictions worldwide, including the EU, UK, US, Korea, Australia, and Brazil.

• How often does an SDS need to be updated?

  Requirements vary by jurisdiction. Under EU REACH and GB regulations, an SDS must be updated without delay when new information becomes available that may affect risk management measures, or when a substance is identified as an SVHC. Under OSHA HazCom 2024 in the US, manufacturers must update SDS within six months of becoming aware of new significant hazard information. Best practice is a formal review at least every three years, with triggered reviews whenever a component substance appears on a regulatory update.

• What are the most common SDS compliance failures?

  The most frequently cited failures across EU, UK, and US regulatory inspections are: outdated hazard classification, missing or incorrect emergency contact numbers, exposure limits that do not reflect current values for the country of use, Section 14 transport classifications that conflict with the GHS classification, and no version control or change management process. For mixture SDS, over-reliance on unverified supplier data is a persistent issue.

• Is one SDS valid in all countries?

  No. GHS is a globally harmonised framework, but each adopting country implements it differently. Revision levels vary, additional local content is often required, and language requirements differ. A US SDS prepared under HazCom 2024 will not satisfy EU CLP requirements. An EU SDS will need adaptation for Korea (K-REACH), Japan (CSCL), Australia (HSIS), and others. Each target market requires a separately authored and reviewed document.

• What happens if an SDS is non-compliant?

  Consequences depend on jurisdiction and severity. They include regulatory fines and enforcement notices, product holds at border or customs, failed supplier audits, and loss of the right to supply. In cases where a non-compliant SDS contributes to a workplace incident, liability exposure for the manufacturer or importer is significant. Regulators in the EU, UK, and US have all increased SDS enforcement activity in recent years.

• What is the difference between GHS and CLP?

  GHS (Globally Harmonised System) is the international framework for classifying and communicating chemical hazards, developed by the United Nations. CLP (Classification, Labelling and Packaging Regulation) is the EU's legal implementation of GHS. They share the same underlying structure but differ in specific requirements, revision levels adopted, and legal obligations. UK REACH and UK CLP are retained versions of EU law that have since diverged following Brexit.

• What should an SDS emergency contact number comply with?

  Requirements differ by jurisdiction. Under EU CLP, the emergency number must connect to a body capable of providing specialist medical advice. Under OSHA HazCom, a number operational during normal business hours is the minimum, with 24-hour cover required for substances presenting immediate health hazards. A general company switchboard number does not satisfy either requirement.

• How do I know if my SDS portfolio is compliant?

  The only reliable way to know is a structured review against current regulatory requirements for each jurisdiction where your products are sold. Common indicators of risk include SDS documents that have not been reviewed in the past two years, portfolios spanning multiple export markets with no jurisdiction-specific versions, and no documented review or change management process. Yordas Group offers a free discovery call with a HazCom consultant to help you identify where your greatest areas of exposure are likely to sit.

Fiona Moir | Managing Regulatory Consultant • Hazard Communication

I head up the Hazard Communication team where we cover all of our SDS, classification, labelling and packaging services. Part of this service comprises the compilation of Safety Data Sheets (SDS) in accordance with global regulations.

I wear multiple hats, from the delivery and ongoing development of service structure, operations and training (internal and external). I also work with multiple departments to help with the development of the Hazel SDS and classification tools (Internal use) and the Helix SDS Manager.

Hayley Lewis | Managing Consultant - Regulatory • Scientific Services

At Yordas, I am a Managing Regulatory Consultant specialising in Biocides and Product Services. I collaborate with clients to discuss their regulatory needs, propose strategies for compliance, and project manage the delivery and implementation of required applications and reviews, ensuring that the companies we work with remain globally compliant with marketing requirements.

This includes supporting clients in marketing cosmetic products, biocidal products, veterinary products, OSPAR products, and more. Our services range from scoping assessments to determine requirements, costs, and timelines—enabling clients to make informed decisions—through to the commissioning of required testing and the preparation and submission of approval applications worldwide.

Further reading

References

1.    Deloitte and The Manufacturing Institute (2021), Creating Pathways for Tomorrow's Workforce Today: Beyond Reskilling in Manufacturing. themanufacturinginstitute.org

2.    OECD (2025), OECD Employment Outlook 2025: Can We Get Through the Demographic Crunch? oecd.org

3.    Cefic, Facts and Figures of the European Chemical Industry. cefic.org

4.    Cefic, Landscape of the Industry: United Kingdom. cefic.org

5.    Chemical Industries Association, People and Skills. cia.org.uk

6.    IChemE (2026), Employment Survey 2025 results. icheme.org