Home / Regulations / Who must provide an SDS REACH Articles 31–36

Who must provide an SDS

Which actor in the supply chain has to provide a safety data sheet, to whom, when and in what form – and what applies to products that do not need one.

Sources last checked: 14 October 2026 Expert review: Bc. Jerguš Sekanina, product certification General information, not legal or professional advice. Always check the current consolidated text on EUR-Lex.

Short answer The supplier. Whoever places a substance or mixture on the market – manufacturer, importer, downstream user or distributor – provides the SDS to the next professional recipient, free of charge, no later than the first delivery. When an SDS is required is explained in our guide.

Duties by role

REACH uses “supplier” for any manufacturer, importer, downstream user or distributor placing a substance or mixture on the market. Each one has slightly different tasks.

First in the chain

Manufacturer and importer

Compiles the SDS. If a chemical safety report is required, the relevant exposure scenarios are attached as an annex to the SDS and the SDS must be consistent with the report.

Formulator, user

Downstream user

Uses the SDS received from suppliers. When compiling an SDS for its own mixture, it includes the relevant exposure scenarios and other information from the SDSs it received.

Reseller

Distributor

Passes the SDS on to its customers, including relevant exposure scenarios. It also has to provide the SDS in the language of the country where it sells.

At the workplace

Employer

Gives workers and their representatives access to the information in the SDS for substances and mixtures they use or may be exposed to (Art. 35).

Source: REACH, Art. 31(1), (2), (7) and Art. 35

How and when to provide it

The same rules apply to every supplier, whatever its role.

Source: REACH, Art. 31(5), (6), (8), (9) and Art. 36

Free of charge, on paper or electronically (Art. 31(8))
No later than the first delivery of the substance or mixture (Art. 31(8))
In an official language of the Member State where the product is placed on the market, unless that state provides otherwise (Art. 31(5))
Dated, with the 16 headings of Annex II (Art. 31(6))
Updated without delay when new information on hazards or risk management becomes available, or after an authorisation or restriction decision (Art. 31(9))
Revised version to all recipients supplied in the preceding 12 months, marked “Revision: (date)” (Art. 31(9))
Kept for at least 10 years after the substance or mixture was last supplied or used, together with the other REACH information (Art. 36)

When no SDS is required

Art. 31(4)

Products for consumers

For hazardous products sold to the general public with enough information for safe use, an SDS is not needed – unless a downstream user or distributor asks for one.

Art. 32

Substances and mixtures without an SDS

The supplier still passes on registration numbers if available, details of authorisation and restrictions, and other information needed for risk management – free of charge, no later than the first delivery.

Art. 33

Articles with substances of very high concern

Articles do not get an SDS. If an article contains a Candidate List substance above 0.1 % w/w, the supplier informs recipients, at least with the name of the substance; consumers receive it on request within 45 days, free of charge.

Source: REACH, Art. 31(4), 32 and 33

Placing a product on the market?

We prepare the safety data sheet you have to provide to your customers, in the languages of the countries you sell in.

SDS authoring Annex II requirements

Sources

Regulation (EC) No 1907/2006 (REACH) – Articles 31 to 36
Commission Regulation (EU) 2020/878 – Annex II
ECHA – Guidance on the compilation of safety data sheets

Sources last checked: 14 October 2026. Always use the consolidated version on EUR-Lex.