Global SDS Regulatory Map: How to Prepare the Right SDS for Every Market

If you manufacture, export, import or sell chemical products internationally, one of the first questions you may ask is: “Can I use the same SDS for every country?”

In many cases, the answer is no.

A Safety Data Sheet (SDS), commonly called an MSDS, is not simply a document containing chemical composition and hazard pictograms. It is a regulatory and technical document that communicates the hazards, safe handling requirements, composition, transport information and regulatory status of a product in a particular market.

The requirements can change depending on:

• Where the product is being sold, imported or used
• The product's composition and concentration of hazardous ingredients
• The intended use and user type
• The applicable GHS revision or national implementation
• Local chemical legislation and regulatory inventories
• Exposure limits and workplace requirements
• Transport classification
• Language and emergency contact requirements
• Product-specific legislation

For example, an SDS prepared for the European Union may need to follow REACH and CLP, while a US SDS must be assessed against OSHA's Hazard Communication Standard. Canada operates under WHMIS, while Australia and New Zealand have their own implementations of GHS.

The United Nations has published GHS Revision 11, but this does not mean that every country has automatically adopted GHS Rev. 11. Countries implement GHS through their own legislation, standards and transition periods.

This is why a Global SDS Regulatory Map is useful.

What Is a Global SDS Regulatory Map?

A Global SDS Regulatory Map is a framework used to determine the regulatory requirements applicable to a product in each target market.

Instead of starting with an SDS template, you start with the regulatory destination.

The basic question is: “Where is the product going, and what regulations apply there?”

Once the destination is known, the SDS author can determine which regulatory framework, classification methodology, language and additional information should be used.

This is particularly important for companies selling products across multiple markets.

For example, one product sold in the European Union, United States, Canada, Australia and Saudi Arabia may require different regulatory assessments and localized SDS versions, even though the underlying product is identical.

Global SDS Regulatory Map by Country

Important: This table is a regulatory starting point. Exact requirements should be verified against the legislation applicable to the specific product, concentration, intended use and market.

Step 1: Identify Where Your Product Is Going

Before preparing an SDS, identify all markets in which the product will be manufactured, imported, distributed, sold, stored or used.

The destination market is critical because chemical regulations are jurisdiction-specific.

• Chemical classification may differ
• Hazard thresholds may differ
• Exposure limits may differ
• Regulatory lists may differ
• Ingredient disclosure rules may differ
• Emergency information may differ
• Language requirements may differ
• Supplier/importer information may differ

An SDS prepared for the EU should not automatically be treated as an SDS for the USA. Similarly, a US SDS should not automatically be used for Canada.

Step 2: Determine Which GHS Version Applies

One of the biggest misunderstandings in global SDS preparation is the belief that the latest GHS revision should always be used.

The United Nations Globally Harmonized System (GHS) is an international model framework. Individual countries adopt and implement GHS through their own legislation.

The UN has published GHS Rev. 11, but countries may legally operate under earlier revisions or national implementations.

For example, New Zealand's hazardous-substance classification system is based on GHS 7. The US OSHA Hazard Communication Standard has its own regulatory implementation and was updated in 2024 with provisions aligning relevant parts of the standard with GHS Rev. 7, along with additional US-specific requirements.

Therefore, do not ask only: “What is the latest GHS version?”

Ask instead: “What GHS revision and national chemical regulation legally applies to my product in the destination market?”

This distinction is critical for international SDS authoring.

Step 3: Understand the Difference Between GHS and Local Chemical Regulations

GHS provides a classification and hazard communication framework. It does not automatically replace national chemical legislation.

A country may use GHS while simultaneously applying additional requirements relating to:

• Chemical registration
• Chemical inventories
• Restrictions
• Authorisation
• Substance notification
• Importer responsibilities
• Exposure limits
• Workplace requirements
• Environmental regulations
• Emergency response

Product-specific legislation

For example, the EU regulatory assessment can involve both REACH and CLP rather than simply a generic “GHS SDS.”

Step 4: Determine Whether the Product Is a Substance, Mixture or Article

Before classification, identify what you are actually selling.

• Pure chemical substance
• Mixture
• Solution
• Adhesive
• Coating
• Paint
• Lubricant
• Cleaning product
• Detergent
• Aerosol
• Industrial chemical
• Laboratory reagent
• Fuel
• Fertilizer
• Pesticide
• Consumer chemical
• Article containing chemicals

This distinction matters because different regulatory rules can apply to different product types. The product should therefore be assessed based on its actual composition and intended use, rather than only its commercial name.

Step 5: Product Composition Is the Foundation of SDS Classification

An SDS cannot be accurately prepared from the product name alone. Classification depends heavily on the actual formulation.

• Chemical name
• CAS number
• EC number where applicable
• Concentration
• Concentration range
• Impurities
• Additives
• Stabilizers
• Solvents
• Active ingredients
• Physical state
• pH
• Flash point
• Density
• Viscosity
• Vapour pressure
• Particle characteristics where relevant
• Toxicological data
• Ecotoxicological data

Why Concentration Matters

A raw material may be classified as hazardous at a high concentration. If that raw material is incorporated into another formulation at a significantly lower concentration, the finished mixture may not necessarily have the same classification.

The finished product must be evaluated according to the applicable mixture classification rules. Depending on the hazard class and applicable legislation, concentration thresholds, additivity rules, bridging principles and other classification methods may determine the final classification.

Therefore, the hazard classification of an ingredient should not simply be copied into the SDS classification of the finished product.

CAS Number Does Not Automatically Mean the Finished Product Has the Same Hazard

A CAS number identifies a substance. It does not, by itself, determine the hazard classification of the finished formulation.

For example, a raw material may be hazardous at 100% concentration, while the finished formulation contains only a small percentage of that ingredient. The finished mixture must be assessed under the relevant regulatory classification methodology.

This is particularly important for adhesives, paints, coatings, cleaning formulations, detergents, lubricants, inks and industrial formulations.

Step 6: Determine the Actual Hazards of the Finished Product

Once the composition is established, determine which hazards actually apply to the finished product.

• Physical hazards: explosives, flammable gases, flammable aerosols, flammable liquids, oxidizing substances, gases under pressure, self-reactive substances, organic peroxides and corrosive-to-metal hazards
• Health hazards: acute toxicity, skin corrosion/irritation, serious eye damage/irritation, sensitisation, mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity and aspiration hazard
• Environmental hazards: aquatic acute/chronic toxicity and other applicable environmental hazard categories

The final classification should be based on the applicable regulatory criteria, not simply on the presence of a hazardous CAS number.

Step 7: Claims in an SDS Should Be Supported by Evidence

An SDS is a technical and regulatory document. Information should be supported by reliable source data.

COA — Certificate of Analysis

A COA can provide information such as:

• Batch number
• Product identity
• Purity
• Assay
• Concentration
• pH
• Moisture
• Density
• Viscosity
• Other product specifications

Other useful supporting documents include Technical Data Sheets, existing SDSs, product specifications, raw-material SDSs, test reports, toxicological data, ecotoxicological data, formulation information, manufacturer declarations and regulatory registrations.

The SDS should be consistent with the manufacturer's technical documentation and available test evidence. A COA does not replace regulatory classification, but it can be an important supporting document for product verification, customer audits and future regulatory requirements.

Step 8: Determine Whether the Product Has a UN Number

Another important part of SDS preparation is determining whether the product is regulated for transportation.

Do not assume that every product with an SDS is dangerous goods, or that a product without an obvious workplace hazard has no transport requirements.

• UN Number
• Proper Shipping Name
• Transport Hazard Class
• Packing Group
• Environmental hazards
• Marine pollutant status
• Special provisions
• Limited quantities
• Excepted quantities

SDS and Dangerous Goods Are Not the Same Thing

An SDS communicates information about the product and its hazards. Dangerous goods regulations determine how regulated products can be transported.

• Air: IATA Dangerous Goods Regulations
• Sea: IMDG Code
• Road: ADR, where applicable
• Rail: applicable rail dangerous-goods requirements

If a product is exported internationally, the transport assessment should be considered separately from workplace hazard classification.

Step 9: Language Is Part of SDS Compliance

Language should not be treated as a cosmetic issue. Depending on the jurisdiction, the SDS may need to be provided in specific language or languages.

• European Union: relevant official language requirements
• Canada: English and French
• China: Chinese
• Japan: Japanese
• South Korea: Korean
• Brazil: Portuguese
• Mexico: Spanish
• Thailand: Thai
• Indonesia: Indonesian

The language requirement should therefore be identified before finalizing the SDS.

Step 10: Check Regulatory Lists and Market-Specific Requirements

Depending on the destination, additional regulatory checks may be required, including:

• Chemical inventories
• Restricted substances
• SVHC
• Authorisation requirements
• Exposure limits
• Occupational regulations
• Environmental restrictions
• National chemical registrations
• Import requirements
• Product-specific legislation

16 Sections of an SDS

The fact that two countries use a 16-section SDS does not mean that their legal requirements are identical. The structure may be harmonized while the content and regulatory requirements remain jurisdiction-specific.

Why SDS Updates Are Important

An SDS should not be treated as a document that is prepared once and permanently reused.

It may need to be reviewed when:

• The formulation changes
• A raw material changes
• Ingredient concentration changes
• A new hazard is identified
• New toxicological information becomes available
• Regulations change
• GHS implementation changes
• Exposure limits change
• A substance becomes restricted
• A new regulatory listing is published
• Transport classification changes
• The product enters a new country

A change in formulation can lead to a change in hazard classification, label information, SDS content and potentially transport classification. SDS compliance should therefore be treated as an ongoing regulatory process.

Global SDS Preparation Workflow

1. Identify the Product: Determine exactly what the product is.
2. Identify the Market: Determine every country where the product will be sold, imported or used.
3. Identify Applicable Regulations: Determine the applicable national and regional legislation.
4. Identify the GHS Implementation: Determine which GHS revision or national classification framework applies.
5. Review Composition: Check ingredients, CAS numbers and concentrations.
6. Classify the Finished Product: Apply the appropriate classification methodology.
7. Assess Transport: Determine whether UN/IATA/IMDG/ADR requirements apply.
8. Localize the SDS: Check language, supplier information, emergency contacts and regulatory requirements.
9. Verify Supporting Evidence: Cross-check the SDS against COA, specifications, test reports and formulation data.
10. Establish a Revision Process: Review the SDS when regulations, composition or hazard information changes.

Global SDS Compliance Checklist

Product

• Product identity confirmed
• Intended use confirmed
• Substance/mixture/article status confirmed
• Complete formulation available

Composition

• CAS numbers verified
• Ingredient concentrations verified
• Hazardous ingredients assessed
• Raw-material SDSs reviewed
• COA reviewed

Regulation

• Destination market identified
• Applicable legislation identified
• GHS revision identified
• Regulatory lists checked
• Exposure limits checked
• Product-specific legislation considered

Classification

• Physical hazards assessed
• Health hazards assessed
• Environmental hazards assessed
• Mixture classification completed
• Concentration thresholds evaluated

Transport

• UN number assessed
• Proper shipping name assessed
• Transport class assessed
• Packing group assessed
• IATA requirements checked where applicable
• IMDG requirements checked where applicable
• ADR requirements checked where applicable

Localization

• Required language confirmed
• Supplier information confirmed
• Importer information confirmed where applicable
• Emergency contact verified
• Local regulatory information reviewed

Verification

• SDS consistent with COA
• SDS consistent with product specification
• SDS consistent with formulation
• Test data reviewed
• Claims supported by evidence
• Revision date included

Why Manufacturers Should Use a Market-Specific SDS Strategy

For companies selling internationally, the most efficient approach is not necessarily to create a completely different technical document from scratch for every country.

Instead, manufacturers can maintain a controlled master product database containing:

• Product formulation
• CAS numbers
• Concentrations
• COAs
• Technical specifications
• Test data
• Existing SDS
• Hazard classifications
• Transport information

This information can then be used to prepare market-specific SDS versions while maintaining consistency between the product data, SDS and supporting technical documentation.

Global SDS Does Not Mean One-Size-Fits-All SDS

A global SDS strategy does not necessarily mean using one SDS for the entire world.

It means maintaining one controlled product information base and applying the appropriate regulatory assessment for each target market.

Master Product Data → Regulatory Assessment → EU SDS / US SDS / Canada SDS / Australia SDS / Saudi Arabia SDS / Other Market SDS

This approach makes it easier to manage regulatory changes and maintain consistency between product information, labels and supporting documents.

Still Confused About How to Author Your MSDS?

Still confused about how to author the right MSDS for your product or which regulatory requirements apply in your target market?

Contact the experts at Instacertify. We will guide you on how to prepare a professional, market-specific MSDS/SDS that is aligned with the applicable regulatory requirements and designed to cover a larger international market.

From product composition and CAS numbers to GHS classification, REACH, OSHA, WHMIS, transport requirements, COA review and market-specific localization, our team can help you determine the right regulatory pathway before the SDS is finalized.

Whether you are a manufacturer, exporter, importer, distributor or marketplace seller, the right SDS starts with understanding the product and the market where it is going.

Contact Instacertify to discuss your product, target markets and SDS requirements.