ECHA REF-11 : Safety Data Sheets and checking the conformity with the requirements of the new Annex II of REACH 

ECHA REF-11 : Safety Data Sheets and checking the conformity with the requirements of the new Annex II of REACH 

ECHA REF-11 : Safety Data Sheets and checking the conformity with the requirements of the new Annex II of REACH 

December 2024 

Summary of the REF-11 Project Report on Safety Data Sheets (SDS) 

Executive Summary: The REF-11 project, conducted in 2023, aimed to assess compliance with the new requirements introduced by Regulation (EU) 2020/878 for Safety Data Sheets (SDS). The project involved inspections across 28 EU/EEA countries, covering 2528 SDS. The primary focus was on the completeness and quality of the information provided in the SDS, including new requirements for nanoforms, endocrine-disrupting properties, and specific concentration limits (SCL), acute toxicity estimates (ATE), and M-factors. 

Key Findings

  • Compliance: 87% of the SDS reviewed complied with the new format required by Regulation (EU) 2020/878. However, a non-compliance rate of 35% was reported, indicating room for improvement. 
  • Nanoforms: 67% of the SDS requiring information on nanoforms did not provide it. 
  • Endocrine Disruptors: 52% of the SDS for substances with endocrine-disrupting properties contained the required information. 
  • SCL, ATE, M-factors: Compliance rates were 82% for SCL, 65% for ATE, and 79% for M-factors. 
  • Specific concentration limits (SCL), multiplication factors for acute and chronic aquatic hazards (M-factors) and acute toxicity estimates (ATE) according to Regulation (EC) 1272/2008 (CLP Regulation) 
  • Quality Issues: Common issues included incorrect or implausible information in sections 1, 2, 3, 8, and 9 of the SDS. 

Enforcement Actions

  • Measures: Enforcement measures included written advice (69%), administrative orders (11%), fines (11%), and criminal complaints (6%). 
  • Follow-up: 59% of follow-up activities were completed during the operational phase. 

Recommendations

  • Dutyholders: Ensure SDS compliance with the latest requirements and improve understanding of SDS obligations. 
  • ECHA/COM: Develop further Q&A and raise awareness among stakeholders, especially SMEs. 
  • NEAs: Continue quality controls on SDS and organize awareness-raising measures. 
  • Forum: Consider a follow-up project to monitor SDS quality improvements. 

Graphs

  1. Compliance Rate for SDS Format:  
  1. Non-compliant SDS Identified Through Different Enforcement Projects:  

The report highlights the need for ongoing efforts to improve the quality and compliance of SDS to ensure safe handling of hazardous substances and mixtures. 

REF-11 project report on: Safety Data Sheets (SDS); December 2024: https://echa.europa.eu/documents/10162/2304648/wg_ref11_project_report_en.pdf/c9c78941-48bf-c6eb-38ca-11e55e18f889?t=1733136406554 

Ekotox Centers SDS webpages: https://ekotox.eu/safety-data-sheet-sds/ 

Ekotox Centers Chemicals Management webpages: https://ekotox.eu/chemicals-management/