We cannot issue a safety data sheet under our own name, and you should be wary of any broker who offers to. Under REACH the duty to supply an SDS falls on the supplier, defined as the manufacturer, importer, downstream user or distributor placing the substance on the market. We are a broker: we never take title and we never place product on the market, so we are not the supplier. Section 1.3 of an SDS has to identify the actual supplier and the competent person behind it. Putting our name there would point a reader at the wrong party in an emergency, which is the one thing the document exists to prevent. What we do instead is make sure the producer's SDS is current, complete and in the right language before it reaches a buyer.
Who has to produce the safety data sheet
The obligation sits with the supplier under Article 31 of REACH, and supplier is defined in Article 3(32) as any manufacturer, importer, downstream user or distributor placing a substance or mixture on the market. In a brokered trade that is the producer or the seller, never the broker.
The document also has a prescribed shape. Annex II of REACH was replaced by Commission Regulation (EU) 2020/878, and since 1 January 2023 every safety data sheet circulating in the EU has to follow that revised format. An SDS in the old layout is not merely dated, it is non compliant, and a careful buyer will send it back.
- Sixteen sections, in the prescribed order. Section 1 identifies the substance and the supplier, section 2 the hazards, sections 4 to 8 the emergency and handling information, section 9 the physical and chemical properties, and sections 14 and 15 transport and regulatory status.
- Section 1.3 names the supplier, with address, telephone and the e-mail of a competent person. This is the field that makes rebranding an SDS a bad idea rather than merely an unhelpful one.
- Section 14 carries the transport classification. UN number, proper shipping name, class and packing group, which is what a forwarder actually works from. For waste-derived oils this varies by material and sometimes by batch, so it has to come from the producer rather than from a general rule.
- The SDS is the producer's document, and usually their copyright. We pass it on, we do not reissue it.
An SDS is not a COA, and buyers get this wrong constantly
These two documents answer different questions and neither substitutes for the other. A surprising number of stalled enquiries come down to a seller sending one when the buyer asked for the other.
| Safety data sheet (SDS) | How to handle the material safely and what to do when it goes wrong. Generic to the product, not to your parcel. No batch number. Required by law for hazardous substances and mixtures. |
|---|---|
| Certificate of analysis (COA) | The measured values for THIS batch, with the test methods and the date. This is the document that decides whether a cargo meets contract. Not required by law, required by the buyer. |
| Typical specification | What the producer expects the material to look like in normal production. Useful for a first conversation, worthless as a contractual basis. Never accept it in place of a COA. |
| Proof of Sustainability (PoS) | The sustainability claim under a recognised scheme, tied to the consignment. Decides whether the volume counts for a mandate. See ISCC certification. |
| Waste documentation | Annex VII or the notification dossier, where the material moves as waste. See waste plastics for what changed in 2026. |
The document pack, in the order people usually need it
- Before anyone quotes: typical specification, origin, monthly volume, and whether the material is certified. Enough to know if there is a trade.
- Before a firm offer: a dated COA from a recognised laboratory, the SDS in current format, and the certification status in writing. A COA older than the parcel is not evidence about the parcel.
- At contract: the agreed specification with tolerances and the test methods named, the inspection arrangement, and who pays for what if the result is disputed. Naming the method matters more than people expect: two laboratories running different methods will disagree and both will be right.
- At loading: independent inspection report, sealed samples retained by both sides, bill of lading, and the sustainability paperwork if the volume is being claimed.
- On arrival: discharge analysis. If it differs from load, the retained samples are the only thing that will settle it. See cargo claims.
What we do with documents, honestly stated
- We check the pack is complete and current before it goes to a buyer, which is usually the difference between a fast answer and three weeks of back and forth.
- We tell you what is missing. Most rejected enquiries we see fail on an absent chlorine figure, an undated analysis, or an SDS in the pre-2023 format, not on price.
- We arrange independent inspection and laboratory work through recognised inspection companies, and we can arrange sampling at load or at discharge.
- We do not issue safety data sheets, certificates of analysis or proofs of sustainability, and nobody should. Those come from the supplier, an accredited laboratory and a certified operator respectively. A document is only worth what its issuer is worth.
Frequently asked questions
Can you provide an MSDS or SDS for the product?
We can obtain the producer's safety data sheet and pass it on, and we check it is in the current format before it reaches you. We cannot issue one under our own name. Under REACH the duty falls on the supplier, meaning the manufacturer, importer, downstream user or distributor placing the material on the market. As a broker we never take title, so we are not the supplier, and section 1.3 of an SDS has to name the party who actually is. A broker who offers you an SDS on their own letterhead is telling you something useful about themselves.
What is the difference between MSDS and SDS?
MSDS is the older term and you will still hear it constantly in the trade. In the EU the correct term is safety data sheet, and the required content and layout are set out in Annex II of REACH as replaced by Commission Regulation (EU) 2020/878. Since 1 January 2023 every SDS circulating in the EU has to follow that revised format. If someone sends you a document headed MSDS in an old layout, ask for a current one before you build a shipment around it.
Is a safety data sheet enough to trade on?
No, and this is one of the most common misunderstandings we see. An SDS describes the product generically and tells you how to handle it safely. It says nothing about your parcel. The document that decides whether a cargo meets contract is a dated certificate of analysis from a recognised laboratory, with the test methods named. Ask for both, and never accept a typical specification instead of a COA.
Do I need an SDS if my material moves as waste?
The REACH safety data sheet duty attaches to substances and mixtures placed on the market, and waste sits outside REACH until it reaches end of waste status. That does not leave you with nothing to produce: waste shipments carry their own documentation, and transport classification still has to be established. See REACH for pyrolysis oil and waste plastics.
What language does the safety data sheet have to be in?
The official language or languages of the Member State where the substance or mixture is placed on the market, unless that state provides otherwise. In practice this means a cargo moving to several countries may need several versions, and it is worth raising early because producers often have only English on file. It is a routine reason for delay at a receiving terminal.
Can you put your company name on the documents?
No, and we would advise against working with anyone who does. Each document in a cargo pack derives its value from who issued it: the SDS from the supplier who bears the duty, the COA from an accredited laboratory that did the work, the proof of sustainability from a certified operator inside a recognised scheme. Rebranding any of them strips out exactly the thing that made it worth having.
Sources and further reading
Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.
Who to ask about Documents and SDS
Ask us. Not sure whether your pack is complete? Send us the list and we will tell you what is missing before a buyer does. We answer the same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian. There is no charge and no obligation for a market read or a second opinion on a specification.
You get Bart van den Brug directly, not a call centre and not a form that goes nowhere. We are an independent broker: we never take title, we do not trade our own book, and we are paid a commission only on business that actually concludes. That is why we will also tell you when the answer is no.
+31 6 115 83 448
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Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Last reviewed 09 August 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.