Application dates and the completed transition
Commission Regulation (EU) 2020/878 replaced Annex II to REACH, which sets the requirements for compiling safety data sheets (SDS). It applies from 1 January 2021. Its derogation allowed SDS not complying with the new annex to continue to be provided until 31 December 2022. That transition has ended. See Articles 1–3 of Regulation 2020/878.
Selected information changes to review
The changes include information concerning nanoforms, endocrine-disrupting properties, and expanded physical and chemical information in Section 9. The required content depends on the substance or mixture and the applicable subsection. Check the supporting data rather than adding standard statements to every product. ECHA’s REF-11 report explains the checks used to assess these SDS requirements.
Section 14 and transport documentation
Section 14 provides basic classification information for relevant transport modes: UN or ID number, proper shipping name, transport hazards, packing group where applicable, environmental hazards and precautions. Subsection 14.7 concerns maritime bulk transport under IMO instruments. Read the requirements in REACH Annex II, Section 14.
An SDS supports a transport review; it does not replace the dangerous goods transport document required by ADR, section 5.4.1. Confirm the classification and documentation for the actual consignment and each transport leg. A general SDS entry alone cannot establish that a shipment qualifies for an exemption.
A practical review of the documents you use
Ask the supplier for the SDS covering the exact product and intended use. Check its revision, supplier identity and relevant exposure scenarios. Compare the information with your workplace arrangements and transport records, and raise gaps or inconsistencies with the supplier. ECHA explains that SDS should be updated without delay when new hazard information or more stringent risk management measures become necessary.
Use ECHA’s compilation guidance alongside the applicable REACH and CLP requirements. The 2020 amendment is a useful reference, while current compliance also depends on subsequent regulatory and product information.
Discuss your operation in Spain
For a review of transport information, provide the product, current SDS, quantities, packaging and transport modes. DGSA advisory services can help identify questions requiring clarification. Contact DGSA before relying on uncertain classifications or exemption assumptions.