SDS & labelling: which languages, for which countries?
SDS & labelling: which languages, for which countries?
mercredi 19 avril 2023
A SDS (Safety Data Sheet) and a label in English are not valid for all European Member States. Indeed, these elements are only accepted for Ireland and Malta. Similarly, the transmission of these elements only in English is not sufficient for products intended for Malta.
What does the regulation say?
Regarding the labelling of products, article 17, paragraph 2 of Regulation (EC) No1272/2008 (CLP) states that:
“The label shall be written in the official language(s) of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide(s) otherwise.”
About the SDS article 31, paragraph 5 of Regulation (EC) No1907/2006 (REACh) specifies that:
“The safety data sheet shall be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide otherwise.”
The SDS and label must be written in the official language(s) of the country where the product is placed on the market. The list of official languages selected by country can be accessed using the following link: https://echa.europa.eu/documents/10162/17217/languages_required_for_labels_and_sds_en.pdf
In addition to the language, some sections of the SDS remain dependent on the country where the product is placed on the market, in particular subsection 1.4 concerning the emergency number, the use of which may require prior registration and payment of fees, section 8 where Occupational Exposure Limit values (OELs) are mentioned and section 15 of the SDS in which certain country-specific regulatory information may appear. This is the case, for example, of the table listing occupational diseases, for SDSs intended for France.
Some details concerning certain countries.
Some countries have specific requirements for SDSs and labels:
• For Finland: when placing a product on the market which is subject to the SDS obligation in Finland, a SDS in Finnish and a SDS in Swedish must be provided. Similarly, the product label must be provided in both languages.
• For Malta: when placing a product on the market that is subject to the SDS requirement in Malta, a SDS in Maltese and a SDS in English must be provided. Similarly, the product label must be provided in both languages.
• For Luxembourg: when placing on the market a product subject to the SDS obligation in Luxembourg, a SDS must be provided in French or German. Similarly, the product label must be provided in French or German.
• For Belgium: depending on the region where the product is placed on the market, the SDS must be written in French, German or Dutch. It is recommended to consult local authorities to check the language(s) of the SDS and label.
Concerning non-EU countries (Switzerland & GB)
For SDSs for Great Britain (since BREXIT) and for Switzerland, a simple translation of an EU SDS into one of the official languages of the country is not sufficient. Indeed, it is necessary to adapt the documents and comply with the regulations in force in the country in question.
As regards the language of the SDSs and labels for Switzerland, there are again some specifications. Indeed, unless the supplier and the professional end-user agree otherwise, the label must be written in at least two official languages (French, German, Italian) and the SDS must be written in one or more of the official languages.
Do not hesitate to contact us for help in preparing the SDSs and labels of your products.
What does the regulation say?
Regarding the labelling of products, article 17, paragraph 2 of Regulation (EC) No1272/2008 (CLP) states that:
“The label shall be written in the official language(s) of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide(s) otherwise.”
About the SDS article 31, paragraph 5 of Regulation (EC) No1907/2006 (REACh) specifies that:
“The safety data sheet shall be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide otherwise.”
The SDS and label must be written in the official language(s) of the country where the product is placed on the market. The list of official languages selected by country can be accessed using the following link: https://echa.europa.eu/documents/10162/17217/languages_required_for_labels_and_sds_en.pdf
In addition to the language, some sections of the SDS remain dependent on the country where the product is placed on the market, in particular subsection 1.4 concerning the emergency number, the use of which may require prior registration and payment of fees, section 8 where Occupational Exposure Limit values (OELs) are mentioned and section 15 of the SDS in which certain country-specific regulatory information may appear. This is the case, for example, of the table listing occupational diseases, for SDSs intended for France.
Some details concerning certain countries.
Some countries have specific requirements for SDSs and labels:
• For Finland: when placing a product on the market which is subject to the SDS obligation in Finland, a SDS in Finnish and a SDS in Swedish must be provided. Similarly, the product label must be provided in both languages.
• For Malta: when placing a product on the market that is subject to the SDS requirement in Malta, a SDS in Maltese and a SDS in English must be provided. Similarly, the product label must be provided in both languages.
• For Luxembourg: when placing on the market a product subject to the SDS obligation in Luxembourg, a SDS must be provided in French or German. Similarly, the product label must be provided in French or German.
• For Belgium: depending on the region where the product is placed on the market, the SDS must be written in French, German or Dutch. It is recommended to consult local authorities to check the language(s) of the SDS and label.
Concerning non-EU countries (Switzerland & GB)
For SDSs for Great Britain (since BREXIT) and for Switzerland, a simple translation of an EU SDS into one of the official languages of the country is not sufficient. Indeed, it is necessary to adapt the documents and comply with the regulations in force in the country in question.
As regards the language of the SDSs and labels for Switzerland, there are again some specifications. Indeed, unless the supplier and the professional end-user agree otherwise, the label must be written in at least two official languages (French, German, Italian) and the SDS must be written in one or more of the official languages.
Do not hesitate to contact us for help in preparing the SDSs and labels of your products.