When to update or revise your safety data sheets (SDS): a global guideUnderstanding regulatory requirements in countries that have adopted GHS

When to update or revise your safety data sheets (SDS): a global guideUnderstanding regulatory requirements in countries that have adopted GHS

Understanding regulatory requirements in countries that have adopted GHS


  • Chemical suppliers must periodically review, and update their SDSs to incorporate new information about hazards, protective measures, or changes in product information.
  • In this post, we provide a summary of the regulatory requirements for SDS revisions in some of the major countries that have adopted the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

As a chemical supplier, it is your responsibility to ensure that your Safety Data Sheets (SDS) are accurate and up-to-date. Revisions may be necessary to reflect new hazard information, new protective measures, or changes to the product information. But when exactly should you revise your SDS?

In this blog post, we will summarize the regulatory requirements for SDS revisions in major countries that have adopted the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). These countries include the European Union (EU), the United States (USA), Canada, China, Japan, Korea, Taiwan, Singapore, and Australia.


REACH Article 31 mandates immediate updates to SDSs when new information on hazards or risk management measures becomes available, when a REACH authorization or restriction is imposed, and after registration.

The revised SDS must be provided to all previous and new recipients of the substance within 12 months, and an incremental numbering system is suggested to identify new versions.

Small changes can be indicated by updating the decimal number, while larger changes require changing the non-decimal number.

REACH does not require periodic SDS reviews.


SDS must be reviewed and updated in the following situations:

  • 1. New significant information concerning a hazardous chemical for which an SDS was submitted has been identified. In this case, OSHA regulations require SDS to be reviewed within three months after noticing the new information and subsequently to be submitted to the appropriate agencies.
  • 2. The hazard classification of a hazardous chemical changes based on the OSHA HCS revisions to incorporate the GHS criteria.

If you receive a modified SDS in the new standardized format, but the hazard classification has not changed, you should check with your state regarding the submission of modified SDS, as each state may have specific requirements for submitting information under EPCRA.


SDS should be updated or revised when the supplier becomes aware of any "significant new data" that changes the hazard classification or ways to protect against the hazards of the product. SDS must be updated within 90 days of the supplier becoming aware of the new information, and this requirement is applicable in Alberta, Manitoba, New Brunswick, Ontario, Prince Edward Island, and Quebec.

The employer's responsibility to update or obtain updated SDS in the workplace is regulated by jurisdiction. In Federal workplace under WHMIS legislation, the employer must actively seek an updated SDS every three years.

If the employer is aware of significant new data, the employer must add this data to the existing SDS. However, it's important to note that the requirement for suppliers to update SDSs every three years, as was the case under WHMIS 1988, is no longer required under current regulations. Therefore, the SDS must be accurate at the time of every sale or importation of the hazardous product.

Workplace Hazardous Materials Information System (WHMIS 2015).


Chinese standards GB/T 16483-2008 and GB/T 17519-2013 mandate that suppliers maintain accurate information in Safety Data Sheets (SDSs). Additionally, the Workplace Rules for Chemical Safety (1997) dictate that manufacturers must revise SDSs every five years or whenever new hazard information is made available and distribute updated versions to recipients within six months.


Starting on April 1st, 2023, it will be required to review health hazards every five years. Should any updates occur, the SDS must be revised and transmitted to downstream recipients within one year.


In Taiwan, a handler who is manufacturing or importing toxic and concerned chemical substances should regularly review, correct and update the contents of safety data sheets. The review process must be examined at least once every 3 years. Additionally, records of updating of content, date, and version, etc. should be kept for three years for future reference. Therefore, handlers in Taiwan must update their SDS information at least once every 3 years.


Safety Data Sheet (SDS) must be reviewed:

  • 1. Within 5 years from the date of issue.
  • 2. When there is new information or a change in the properties of any chemical.


Manufacturers and importers of hazardous chemicals must review and update the information in an SDS every 5 years.

All SDS must list the date when it was last reviewed and updated. This date is usually written in “Section 16 – Any other relevant information”, of the SDS.