A safety data sheet is out of date as soon as the hazard classification behind it changes, whether or not anyone has edited the formula. Most SDS update processes start from a formula change, so the other two triggers, a raw material being reclassified and a regulation adding a hazard class, are the ones that slip through. On 1 November 2026 the EU delivers both at once: substances already on the market must be classified against six new CLP hazard classes, and the mixtures made from them follow by 1 May 2028.
Three things that can make an SDS wrong
An SDS describes a mixture as it was classified on a given date, using the hazard data available on that date. Three different events can make it inaccurate:
- The formula changes. A new ingredient, a different concentration or a substituted raw material changes the mixture calculation.
- An ingredient's classification changes. A supplier revises its own SDS, or a harmonized classification is added to CLP Annex VI. Your formula is identical, but the hazard data feeding the calculation is new.
- The rules change. A regulation adds hazard classes or moves concentration limits, so the same data now produces a different classification.
Change control in most R&D organizations is built around the first event. A formula revision goes through review, and updating the SDS is a step in that review. The second and third events arrive from outside the lab, usually as a supplier email or a regulatory bulletin, with no formula revision to attach them to. Nobody opens the record, so nobody recalculates.
What changes in the EU on 1 November 2026
Commission Delegated Regulation (EU) 2023/707 added six hazard classes to CLP. They cover endocrine disruption and substances that persist, accumulate or move through water. Under Annex I of the regulation, a mixture is classified when it contains:
- Endocrine disruption, human health (EUH380 for Cat. 1, EUH381 for Cat. 2): at least 0.1% of a Category 1 substance or at least 1% of a Category 2 substance.
- Endocrine disruption, environment (EUH430 for Cat. 1, EUH431 for Cat. 2): the same limits, 0.1% for Category 1 and 1% for Category 2.
- Persistent, bioaccumulative, toxic (PBT, EUH440) and very persistent, very bioaccumulative (vPvB, EUH441): at least 0.1% of a PBT or vPvB substance.
- Persistent, mobile, toxic (PMT, EUH450) and very persistent, very mobile (vPvM, EUH451): at least 0.1% of a PMT or vPvM substance.
The classes apply in two waves. According to ECHA, substances placed on the market from 1 May 2025 had to comply immediately, and substances already on the market have until 1 November 2026. For mixtures, the dates are 1 May 2026 for new products and 1 May 2028 for existing ones.
The gap between those dates matters most. Suppliers have until 1 November to reclassify their substances, and their revised SDSs will reach formulators over the following weeks. The 18 months after that are the time formulators have to work out which of their own products those revisions touch.
US teams are on a parallel clock. OSHA's update to the Hazard Communication Standard took effect on July 19, 2024. After a four-month extension published in January 2026, manufacturers and importers had until May 19, 2026 to update labels and SDSs for substances, and have until November 19, 2027 for mixtures.
Where the 0.1% limit falls in a real batch
In a 25 kg pail of coating, 0.1% is 25 g. Additives used at that level, such as preservatives, stabilizers and catalysts, are easy to overlook because they are minor by weight.
Take a coating that contains 0.5% of a substance newly classified as ED HH Category 2. That is below the 1% limit, so the mixture is not classified for endocrine disruption and EUH381 stays off the label. It is above 0.1%, though, and Annex I then requires an SDS to be available on request. If that coating was otherwise unclassified and shipped without an SDS, it may need one after 1 May 2028, with no change to its classification or its formula.
Titanium dioxide changed twice without a formula change
Delegated Regulation (EU) 2020/217 classified titanium dioxide as a suspected carcinogen by inhalation (Category 2, H351) in powder forms containing 1% or more of particles 10 μm or smaller. The classification applied from 1 October 2021, and mixtures containing 1% or more titanium dioxide needed new warning statements on their labels. The EU General Court annulled the classification on 23 November 2022, and the Court of Justice upheld that annulment on 1 August 2025. Companies that updated their documentation in 2021 had to revisit the same products again, and none of those formulas had changed.
How do you find every SDS a reclassification touches?
You work backwards from the substance: list every product that uses it, check each concentration against the new limits, and reissue the SDSs whose classification or on-request status has changed. The first step is where most teams stall. These checks show whether your records can support it:
- Pick one raw material and time how long it takes to list every current product that contains it, with concentrations.
- Open a few SDSs and see whether each records the formula version and the supplier SDS revisions it was built from. Without that, you can't tell whether a sheet predates a supplier change.
- Ask who receives supplier SDS revisions and what happens to them next. If the answer is a shared inbox, the trigger has nowhere to go.
- Find a raw material you buy from two suppliers and compare how each one classifies it.
This is the same where-used question that a restricted substance raises, and the reason product lifecycle management for formulated products tracks which products and intermediates use each material.
What this means for R&D and product stewardship leaders
- When a supplier reclassifies a raw material, who owns finding the affected products: R&D, product stewardship or regulatory?
- Do your SDS update triggers include supplier revisions and regulatory changes, as well as formula changes?
- Of the products you plan to sell in the EU after May 2028, which contain a substance that could fall into one of the new classes, and at what concentration?
- If a classification is reversed, as titanium dioxide's was, could you find the same products a second time?
Keeping each SDS tied to the formula behind it
In Uncountable, each SDS section is drafted linked to the formula, recipe or BOM it covers, so reviewers know which version a sheet describes. GHS hazard data sits on each chemical's record, and regulatory lists are kept as versioned reference data matched to materials by CAS number. When a regulatory source updates a limit, every recipe already checked against it is screened again, so the impact of the change can be assessed across affected formulas. SDS support is currently available for the United States, with EU support planned by the end of 2026. See how SDS authoring and regulatory management work together.
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