The European CLP (Classification, Labelling and Packaging) and REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulations, together with other EU-wide and national regulations, form the complex framework of chemicals legislation in the EU. To ensure we continue to meet these requirements comprehensively, efficiently and in a timely manner, we are consistently developing our hazardous substances management system and are adopting a new, technologically future-proof platform. In this way, we are laying the foundations to implement regulatory changes reliably and efficiently for you in the future.  

The switch to a new hazardous substance management system will result in system-related changes that will not affect the quality of the SDSs. However, there may be changes to the safety data sheets. Our aim is to keep these changes to a minimum and to coordinate them closely with our customers. We always keep the usual high standards of quality and legal certainty in mind.

The order in which UMCO will migrate each customer to the new hazardous substance management system is determined by an assessment of internal processes and technical guidelines. We will contact you in good time should we have any questions regarding your migration in advance.

The SDS format is defined in the EU by Annex II of the REACH Regulation. This format will remain unchanged in the new system. Whilst minor adjustments to the paragraph structure or data layout may alter the visual appearance, the information content remains unchanged.

This feature will remain available, although the logos may be resized during printing. If the display no longer appears as clear as usual, this can usually be resolved by providing the relevant logos in an adjusted graphic quality.

Please note: We will no longer be able to implement corporate identity designs that go beyond the logo in the header of the safety data sheet. Should this affect you, we will contact you.

In the new hazardous substance management system, we primarily rely on the standard phrases and texts from the www.esdscom.eu project. This project is supported by the ACEA (European Automobile Manufacturers’ Association) and has set itself the task of establishing and managing a voluntary industry standard for texts in safety data sheets. This initiative will also play an important role in the expanded dissemination of safety data sheet information – as part of the development of the digital product passport.

We always ensure that the relevant sections of the safety data sheet maintain consistent clarity. We will continue to provide product-specific information, such as recommended storage temperature or specific personal protective equipment, based on existing data.

With this system change, we will in future be able to access both the REACH study results published by ECHA and the ‘most useful classification’ from ECHA’s Classification and Labelling Inventory. This comprehensive expansion of data will further enhance the high quality of our safety data sheets.

However, this may also mean that supply chain information differs from this data. In justified cases, it will still be possible to adjust the classification of substances on a case-by-case basis.

The content of this section is derived from specific product data and the calculation rules prescribed by the CLP Regulation. This is generally based on the data on the substances used, as determined under REACH, and the composition of the formulations. Due to the expansion of the substance database, changes to REACH dossiers and access to data from the ECHA’s REACH Study Results, recalculation may lead to changes in the CLP classification. We carefully check these changes for validity. Our aim is to keep these changes to a minimum for you.

For each hazard classification, the CLP Regulation provides a selection of P-phrases to ensure that users have an appropriate and quick overview of how to handle chemical products safely. To make the selection process easier for safety data sheet authors and to keep the choice of safety instructions as consistent and limited as possible, the ECHA provides comprehensive guidance. With the switch to the new hazardous substance management system, we are moving from partial automation to a fully automated assignment of P-phrases in accordance with ECHA’s guidelines. This guarantees consistent quality and increases legal certainty.

Despite these requirements, there are always several options for formulating safety instructions for each product classification. Here too, our aim is to keep changes to a minimum for our customers and to maintain close coordination.

We constantly review our past decisions and, as a result of changes in the law and our reassessment of these, may conclude that we need to adjust certain details. This may lead to changes in the listing of substances and is carried out with the utmost care and in accordance with legal requirements.

In future, we will be making greater use of data from ECHA. With over 23,000 substances (as of 2024) registered in the EU, it may be the case that the supply chain has been slow to respond to requests for information and that information has not been provided in a timely manner. As a result of the comprehensive updating of the data, this may lead to changes in substance classifications when listing the components in Section 3.

An ATP is a delegated act used to regularly update the CLP Regulation in line with new scientific and technical findings (e.g. new or updated harmonised classifications in Annex VI).

We will continue to incorporate these ATPs into the new system and take them into account when preparing safety data sheets. Outdated data will be updated to comply with current legal requirements during the system migration. We will contact you in the event of any major changes.

The versioning is carried over from the existing SDS documents and recreated with a new major version in the new hazardous substance management system. For technical reasons, it is not possible to reference the previous version from the old system. In the first version of the safety data sheet from the new hazardous substance management system, there will be no change markers at the amended points.

The provision of safety data sheets via the familiar SDS download page is currently being updated to meet the ever-increasing requirements for cyber security. This may affect, for example, the length and rules for passwords, or the frequency of password changes. If you obtain exposure scenarios for your safety data sheets from us, you will in future find these directly as an attachment to the safety data sheet and will no longer need to download them separately. You can access the SDS download page as usual using your existing login details. Instructions on how to use the site can be found after logging in under the ‘Help’ menu item.

The safety data sheet contains, in Section 2, the information required for the creation of hazardous substance labels in accordance with CLP. Changes to the safety data sheet, and in particular to that section, usually necessitate adjustments to the labels, as the information in both documents should be consistent. We endeavour to keep such changes to a minimum. Should this prove unavoidable, we will contact you to agree on the next steps.

We will transfer your existing PCN notifications to the new system. Based on the current findings of the technical analysis, we will be able to complete the migration without the need to assign a new UFI. Should a new UFI unexpectedly be required, we will contact you before submitting the notification.

The format of the extended safety data sheet is regulated under REACH. As part of the system change, we will implement the latest updates to the format of the exposure scenario. These updates will not affect the content. Changes to phrase texts are possible due to the new phrase catalogues. In future, you will find the exposure scenario as a direct annex to the SDS and will no longer need to download it separately.