REACH supplier-information handoff: SDS, non-SDS information and version updates
An only-representative appointment does not replace a substance-specific supplier-information assessment. Articles 31 and 32 distinguish safety data sheets from information supplied when an SDS is not required. Prepare classification, composition, uses, recipients and version history, then assign the actual supplier and representative tasks separately.
Evidence retrieved 2026-10-06. Source versions and topic-specific limits are listed below.
Sourced criteria · EU
What changes the service scope?
Decision or task
What the source describes
What to prepare
Which information route has supporting facts?
What the source describesArticle 31 describes SDS conditions, including hazardous substances/mixtures, specified substance properties/listing and on-request mixture cases. Article 32 addresses specified information where an SDS is not required. [2][3]
What to prepareCollect composition, substance identity, classification, relevant listing/property evidence and the supply context. Request a reasoned SDS-versus-non-SDS conclusion; a CAS match or absence of a hazardous label is insufficient.
Does the document match the supplied product and use?
What the source describesArticle 31 addresses consistency with relevant chemical-safety assessment information, stated SDS headings, language and relevant exposure-scenario handoffs. [2]
What to prepareReconcile the supplied substance/mixture, approved document version, destination language and covered uses. Identify missing supplier or exposure information without declaring an unsupported safe-use conclusion.
Who receives a changed version?
What the source describesArticles 31(9) and 32(3) describe update triggers involving new hazard/risk-management information, authorisation and restrictions, and communication to the specified former recipients. [2][3]
What to prepareMaintain version dates, update reasons, recipient/supply history and evidence of distribution. Test a changed-hazard or restriction scenario against the actual applicable provision.
What does the only representative maintain separately?
What the source describesArticle 8 describes the eligible appointing actor, representative’s importer obligations and maintained quantities/customer and latest-SDS-update supply information. [1]
What to prepareReconcile the appointment’s substances/importers/quantities with supplier-information owners. Identify handoff gaps and exclusions in the quote; do not imply every SDS or downstream duty transfers by appointment.
This guide does not classify a substance, prescribe an SDS for every mixture or determine complete REACH/CLP obligations. Concentrations, identity, properties, supply roles, uses and current legal-list/version facts need review. The acquired dated provisions are the evidence boundary; historical transition text is not presented as a current deadline.
Use this evidence and handoff matrix
Use this checklist to gather your business or product details before speaking with a specialist. The items below explain what to record and suggest useful supporting documents. You can add your own answers in the editable project brief.
Which information route has supporting facts?
Collect composition, substance identity, classification, relevant listing/property evidence and the supply context. Request a reasoned SDS-versus-non-SDS conclusion; a CAS match or absence of a hazardous label is insufficient.
Useful evidence: Composition/identity evidence, classification rationale, relevant official list evidence and recipient/use facts.
Does the document match the supplied product and use?
Reconcile the supplied substance/mixture, approved document version, destination language and covered uses. Identify missing supplier or exposure information without declaring an unsupported safe-use conclusion.
Useful evidence: A product-to-document/use/language matrix and justified exposure-information gaps.
Who receives a changed version?
Maintain version dates, update reasons, recipient/supply history and evidence of distribution. Test a changed-hazard or restriction scenario against the actual applicable provision.
Useful evidence: Revision/change log, recipient history, distribution evidence and update ownership.
What does the only representative maintain separately?
Reconcile the appointment’s substances/importers/quantities with supplier-information owners. Identify handoff gaps and exclusions in the quote; do not imply every SDS or downstream duty transfers by appointment.
Useful evidence: Appointment coverage, importer/quantity reconciliation and supplier–representative responsibility matrix.
Work packages and dependencies
Conditional: REACH supplier-information handoff: SDS, non-SDS information and version updates — Review the stated source/task matrix, actual deciding facts and evidence gaps. Agree the covered entities, products, deliverables, owners and exclusions before engagement.
Questions for providers
Which facts support the selected information route and which remain unresolved?
Which supplied uses and languages are covered, and what source information is missing?
How do you identify affected recipients and demonstrate that the correct update reached them?
Which importer tasks and information updates are inside this appointment, and which remain with other actors?
Sources and data dates
Read the official document in context. The audit details identify the precise locators and preserved versions used for this page.
