A safety data sheet is read when someone handles, stores, transports or responds to an incident involving a substance or mixture. Its translation must survive use on the factory floor, not just a desk review.
In brief
- Article 31(5) of Regulation (EC) No 1907/2006 requires the SDS in an official language of the Member State where the substance or mixture is placed on the market, unless that state provides otherwise.
- Article 31(6) sets the sixteen headings, and Annex II sets out the detailed compilation requirements.
- Each language version must match the correct formulation and revision date, and agree with the CLP label.
The language rule in REACH
Regulation (EC) No 1907/2006 (REACH) sets out when a supplier must provide a safety data sheet (SDS). Article 31(5) says it must be supplied in an official language of the Member State where the substance or mixture is placed on the market, unless that state provides otherwise.
Article 31(6) specifies the sixteen headings, from identification and hazards through first aid, handling, exposure controls and transport to regulatory information. Annex II sets out the detailed compilation requirements, as amended. The European Commission’s REACH overview ↗ gives background on the Regulation.
An SDS is not required in every circumstance for every product. The regulatory owner determines applicability and the content. Once an SDS is required, however, the destination language is not a mere preference.
Article 31(9) also provides for prompt updates in specified situations; recipients supplied in the preceding twelve months must receive the revised dated version.
Why simple translation is insufficient
A substance name, concentration range, exposure limit and emergency instruction may appear in different sections and on the CLP label. If terminology drifts, the same hazard can seem to describe different conditions.
A stale phrase may survive in section 7 while section 2 has been updated. Tables, units, abbreviations, national exposure limits and the identity of the supplier need deliberate checking.
For a distributor serving several Member States, one master SDS can drive many languages, but each market version must be tied to the correct formulation and revision date. The document also has to be usable by the intended professional reader under time pressure.
Build an SDS translation package
- Supply the approved source SDS and the exact formulation, classification and revision history.
- Specify markets and check language, national values and contact information with the responsible chemical safety team.
- Preserve the sixteen-section structure and cross-references, including table values and units.
- Cross-check the CLP label against identifiers, hazard statements and precautionary instructions.
- Release controlled files with the revision date and a record of recipients who need an update.
OMADA can translate and revise the approved document and reconcile terminology across the label and SDS. Chemical classification and regulatory approval remain with the responsible specialists.
Related reading: how we support regulatory affairs teams that track defined terms and changes across document revisions.
Primary legal text: Regulation (EC) No 1907/2006 ↗ (Article 31(5), (6) and (9); Annex II). Further reading: European Commission: REACH Regulation ↗. This article explains selected language provisions and does not replace a product-specific regulatory assessment.