A Comparative Analysis of SDS Standards between China, Europe and the United States

In general, (M)SDS writing norms in these three countries or areas, EU, China and USA, are based on the United Nations' GHS standard. Both the EU and China maintain all 16 sections in a complete Safety Data Sheet consistent with the UN GHS, while the US SDS adopts only 12 sections, i.e. Section 12/13/14/15 are not mandatory as in the other two countries.

There are also slight differences in certain sections so that each version may better integrate into corresponding chemical management institution. For example, in the production information, it is required that the REACH registration number shall be provided in a CLP-compliant SDS if available; for company information, CLP SDS demands contact information of the supplier(s) within the EU while Chinese SDS makes necessary a 24/7 emergency telephone; as to the toxicological information, the US OSHA would specify whether the substance is listed in the National Toxicology Program (NTP) Report on Carcinogens or International Agency for Research on Cancer (IARC) Monographs.

Most important, your hazard classification must be determined and provided in the second section according to relevant GHS standards of the corresponding country. In China, it is specified in the 26 GB standards (Safety rules for classification, precautionary labeling and precautionary statements of chemicals); in the EU areas, DSD/DPD classification or CLP classification or both should be adopted, depending on your actual transitional period; in the US, the OSHA HCS standard is decisive.

It is highly recommended to have a careful study on pertinent SDS regulations or standards of your target market before cargo shipment is on the way - More often than not you need a localized SDS ready on hand for the destination Customs check.

Detailed comparison of three versions of SDS norms, please download Here.

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