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Safety data sheet retention: ten years from the last supply

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

At least ten years, counted from the last manufacture, import, supply or use of the substance or mixture (Article 36 REACH). The period does not start with the date on the data sheet. It starts when you stop supplying the product. Superseded versions have to be kept too.

Art. 36 REACH

Timeline: the issue date of a version starts no period. From the last manufacture, import, supply or use you keep every version for at least ten years.
Keep for at least ten years from the last supply, not from the date on the data sheet (Art. 36 REACH).

What you must keep

Article 36 requires you to keep all the information you need for your REACH duties. That includes every version of the safety data sheet you actually delivered. Only then can you show later what information a customer had at a given time.

Article 49 CLP additionally requires you to keep the information on classification and labelling for ten years.

A worked example

You supply an assembly adhesive until March 2027 and then delist it. The safety data sheet existed in the 2019, 2022 and 2025 versions. You keep all three until at least March 2037, which is 18 years after the first version.

Timeline to scale: safety data sheet versions 2019, 2022 and 2025, last supply March 2027. All three versions stay in the archive until at least March 2037, 18 years after the first version.
The period runs from the last supply in March 2027 and covers all three versions (Art. 36 REACH).

How to do it in practice

  • Never overwrite: a new version is a new file, and the old one moves to the archive
  • Record validity: from when to when was each version current?
  • Note the discontinuation date on the product: the ten years run from here
  • Keep the archive independent of the website: a relaunch must not delete a version

Frequently asked questions

Does retention also apply to distributors?

Yes. Article 36 applies to every actor with REACH duties, including distributors who pass on safety data sheets.

Is it enough to keep the current version?

No. Superseded versions show what customers received earlier. Archive them with their period of validity.

In what form must I keep them?

REACH prescribes no form. Electronic is enough as long as the documents are unchanged and legible and you can produce them quickly when an authority asks.

With ProofPass

ProofPass never overwrites. A new version moves the old one to the archive with its validity period, and the discontinuation date on the product starts the ten years.

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Sources

As of 31 October 2026. The legal text in force prevails. This page is not legal advice; sources are given above.