Documents, safety data sheets and what a cargo needs

No. Under Article 3(32) of REACH a safety data sheet comes from the supplier, meaning the party actually placing the substance on the market. A broker is not a supplier and may not issue one under its own name. We publish clearly marked specimen sheets so you can see what a complete one looks like, but only your actual supplier can give you the real document.

Sections 9, 14 and 15: physical and chemical properties, transport information, and regulatory information. Those are exactly the ones a terminal or a carrier will ask about, so a sheet that is thin there will stop your cargo rather than your paperwork.

A dated laboratory analysis, the sustainability certificate under the relevant scheme with the scope visible, the safety data sheet from the supplier, and for animal by-products the category and the approval number of the establishment. For imports, add the health certificate. Having these ready shortens a negotiation from weeks to days.

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.

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.

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.

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.

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.

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.