Is a chemical register mandatory?
Yes. EU law requires every employer to establish which hazardous substances are present and to assess their risks. In the Netherlands the Arbobesluit adds that an overview of those substances, with a reference to each SDS, is attached to the risk assessment (RI&E). That overview is the chemical register.
Source: Directive 98/24/EC art. 4; in the Netherlands: Arbobesluit art. 4.2(9); Arbowet art. 5Last checked on 31 October 2026
What the law says
The Chemical Agents Directive (98/24/EC) asks every employer in the EU to first determine whether hazardous chemical agents are present at the workplace and, if so, to assess the risks, taking into account the hazards, the supplier's information such as the SDS, the exposure and the quantities (article 4). The Netherlands implements this in the Arbowet, which requires a written risk inventory and evaluation (RI&E, article 5), and in article 4.2 of the Arbobesluit, which lists what the assessment covers for hazardous substances. Paragraph 9 of that article asks for an overview of those substances attached to the RI&E, with a reference to the SDS for each substance. The assessment is reviewed regularly, and in any case when changed circumstances call for it. The word register does not appear in the law; the overview does.
What this means in practice
A chemical register is the list of all products with hazardous substances used or stored in the company, plus the substances that arise during the work itself. For each product it holds the supplier, the SDS with its revision date, the hazard classification, where and what it is used for, and the quantity. The form is free. The register does have to be complete and current, so every new product goes in and every new SDS version is processed. The register is the basis for everything else: without a complete overview you cannot rely on the risk assessment, the workplace instruction cards or the labels.
How Chemspark does it
Upload the SDS and Chemspark puts the hazards, composition, limit values, supplier and revision date in the register. No retyping; you check what was read. Each product carries its screening, risk assessment and the check against the regulatory lists, and the whole register exports as CSV or PDF for the risk assessment file. See what the register holds.
Frequently asked questions
- Can the register be a spreadsheet?
- Yes. The law prescribes no form, only that the overview belongs with the risk assessment and refers to the SDS of each substance. In practice, keeping it up to date gets hard as the number of products, suppliers or sites grows.
- What must it contain at a minimum?
- By law: the hazardous substances, with a reference to the SDS for each. For a usable assessment, add per product the hazards, the use, the location and the quantity; limit values and composition are usually in the SDS itself.
- Does this apply to a small company too?
- Yes. The duty to assess applies to every employer, and the overview of hazardous substances belongs with it as soon as employees can be exposed to them. The size differs, the duty does not.
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