When you must update a safety data sheet
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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
You update a safety data sheet without delay as soon as new information on hazards or protective measures is available, an authorisation is granted or refused, or a restriction is imposed (Article 31(9) REACH). The new version goes free of charge to every recipient you supplied in the previous twelve months. A safety data sheet has no fixed expiry date.
Art. 31(9) REACH
The three triggers
Article 31(9) names three cases in which you revise the data sheet without delay:
- New information that may affect risk management measures, or new information on hazards
- An authorisation was granted or refused
- A restriction was imposed
Common occasions in practice
- A changed harmonised classification of an ingredient (adaptations of the CLP Regulation to technical progress)
- New substances on the Candidate List
- New occupational exposure limits
- A change of formulation
- New format requirements, most recently Regulation (EU) 2020/878 on Annex II
Who receives the new version
Every recipient you supplied in the last twelve months, free of charge. Date the new version. Annex II requires you to mark changes against the previous version, usually in section 16.
Without a distribution list per product you would have to reconstruct from invoices who was supplied. A list that triggers automatically with every new version saves that work.
Frequently asked questions
Must I renew a safety data sheet every few years?
No, REACH has no expiry date. Many companies still review their data sheets regularly, for example every three years, because classifications and limit values change.
What does “without delay” mean?
Without culpable hesitation. The Regulation names no fixed period. It depends on how fast a careful revision is possible.
Must I inform customers who have not bought in more than twelve months?
Not under Article 31(9). Many manufacturers send the new version to all known recipients anyway. It is simpler and safer.
With ProofPass
In ProofPass you upload the new version once. Everyone on the distribution list of the product gets it with a personal link, and the log shows who has opened it.
The dashboard and the sign-up form are in German.
Sources
As of 31 October 2026. The legal text in force prevails. This page is not legal advice; sources are given above.