Start with the product and the journey
Confirm that the safety data sheet (SDS) describes the product being shipped: supplier, product identifier, formulation or concentration where relevant, and physical form. Record its version and revision date. A similarly named product or an earlier formulation is a poor basis for reviewing the consignment.
List every transport leg, including road movements to a port or airport. Establish whether the goods are carried in packages, tanks or another form of containment. A product-level SDS does not record the quantities, package arrangement or route of every delivery.
Read Section 14 for each relevant mode
REACH Annex II, Section 14 specifies basic transport classification information. Review the UN or ID number, proper shipping name, transport hazards and subsidiary risks, packing group where assigned, environmental hazards and precautions.
Check that the information covers the relevant ADR, RID, ADN, IMDG or ICAO requirements. For example, a road classification entry does not establish all the information needed for a sea leg. Subsection 14.7 specifically concerns maritime transport in bulk under IMO instruments; it is not a general bulk-road approval.
Where transport information is unavailable or irrelevant, the SDS must say so. An empty subsection or an unexplained statement that transport is unregulated needs clarification before it is relied upon.
Build the transport record for the consignment
Under ADR 2025, consignor duties in section 1.4.2.1 include ensuring an ADR-compliant consignment and providing the carrier with the required information and documents. The SDS does not replace the dangerous goods transport document required by section 5.4.1.
Use the verified classification alongside shipment details: consignor and consignee, quantities, package number and description where applicable, and any additional entries required for the goods and operation. Other modes have their own documentary requirements. The UNECE ADR interpretation list also explains that the recorded quantity should allow the amount present in the vehicle to be assessed.
Resolve gaps without guessing a classification
Compare the transport information with relevant product data elsewhere in the SDS. A discrepancy is a reason to ask for supporting evidence; CLP hazard statements or a workplace pictogram alone do not supply an ADR UN number.
ECHA encourages recipients to raise SDS inaccuracies or inconsistencies with their suppliers. Explain the exact product, transport modes and conflicting entries, and request a corrected sheet or documented clarification. Use competent classification support when necessary.
A packing group, limited quantity treatment or other exemption must be established under the applicable transport provisions and shipment conditions. Do not select these by default from a generic SDS statement. If the material has changed through use, mixing or contamination, establish whether the original product data still describe it.
Prepare an effective transport review
For DGSA advisory support, provide the current SDS, product details, quantities, packaging, modes and a sample transport document. Keep unresolved questions visible before scheduling carriage. Our REACH SDS updates guide covers the separate changes to SDS compilation requirements. Contact DGSA to review the practical transport documentation.