Safety data sheet in an online shop: who has to get one?
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
A safety data sheet in an online shop is due for business customers, and as a rule not for consumers. The general public need not be supplied with one if sufficient information is provided some other way (Article 31(4) REACH). In a B2B shop you supply it actively; on the widely held reading a download alone does not count.
Art. 31(4) and (8) REACH
B2B: business customers
If you sell substances or mixtures classified as hazardous to business customers, they receive the data sheet no later than the first supply, free of charge, on paper or electronically (Article 31(8) REACH). New versions go to all recipients of the preceding 12 months (paragraph 9).
A download link in the shop is convenient, but on the widely held reading it does not replace supplying the data sheet. Send it by email or personal link.
B2C: consumers
Consumers belong to the general public. They need not be supplied with a data sheet if sufficient information is provided some other way, for example on the label (paragraph 4). If a downstream user or distributor requests the data sheet, they get it.
Check whom your shop really serves. Treat business buyers as B2B customers.
What else applies to online sales
The CLP amendment, Regulation (EU) 2024/2865 (in force since 10 December 2024), adds information requirements for distance sales offers. Their application for advertisements and distance sales was moved to 1 January 2028 by the “stop the clock” Regulation (EU) 2025/2439. Check in advance which label elements your offer shows today.
What to set up in the shop
Separate the customer groups.
- Ask at registration whether the customer buys for a business or privately.
- Business customers: send the data sheet with the first delivery and record that you did.
- Consumers: state the types of hazard in the offer today (Art. 48 CLP); from 1 January 2028 show all label elements (Art. 48a CLP).
- Supply the data sheet to distributors and users on request.
- Send new versions to all recipients of the preceding 12 months.
Frequently asked questions
Does a consumer have to receive a safety data sheet?
As a rule not, if sufficient information is provided some other way (Article 31(4) REACH). Distributors and downstream users can request it.
Is a download in the shop enough for business customers?
On the widely held reading, no. Supply it actively, for example as an email attachment or personal link.
Does the data sheet have to go with every order?
No. No later than the first supply, and after that each new version to all recipients of the preceding 12 months.
With ProofPass
In the safety data sheets module every data sheet hangs on a product page with a QR code. You add business customers to the distribution list. They get the data sheet by email, and ProofPass records when they opened it.
The terms and legal notices are in German, and the German version is binding.
Sources
As of 11 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.