What should I do when the supplier sends a new SDS version?
Compare the new version with the old and check which documents depend on it: the register, the risk assessment, the workplace instruction card and the label. A new version does not always mean new work, but the law expects you to review the assessment when the changes call for it.
Source: REACH Regulation art. 31(9) and Annex II; Directive 98/24/EC art. 4 and 8; in the Netherlands: Arbobesluit art. 4.2(5) and (8), art. 4.10d(4)Last checked on 31 October 2026
What the law says
Under REACH the supplier updates the SDS without delay as soon as new information on the hazards or the control measures becomes available, and as soon as an authorisation or a restriction applies to a substance (article 31(9)). The new version is marked 'Revision: (date)' and goes free of charge to everyone who received the product in the previous twelve months. The changes must be indicated in section 16, unless they are indicated elsewhere in the SDS (REACH Annex II, point 0.2.5). For the employer, the Chemical Agents Directive (98/24/EC) requires the risk assessment to take the supplier's information into account and workers to be informed again when a significant change affects that information. In the Netherlands the Arbobesluit says the same: the assessment is reviewed when changed circumstances call for it (article 4.2(5) and (8)) and the information to workers is updated (article 4.10d(4)).
What this means in practice
First check that it really is the same product: product name, article number and supplier. Then compare the new version with the old, starting with section 16, and look especially at the classification (H-statements, signal word, pictograms), the composition, the limit values and the physical data. If only an address or a date changed, recording the new version is enough. If the classification, the composition or a limit value changed, the risk assessment, the workplace instruction card and the label need another look, and workers must be informed if their instructions change. Keep the old version with the assessment that was based on it, so you can later show which information a decision was based on.
How Chemspark does it
On 'Replace SDS' Chemspark first checks that it is the same product; then you see field by field what changed, and Chemspark marks which risk assessment, workplace instruction card or label needs another look. The old version stays in the version history. You decide what needs redoing and update it. Read more about SDS management in Chemspark.
Frequently asked questions
- Should I keep the old version?
- Yes, that is wise. A risk assessment or workplace instruction card is based on a particular version, and with the old version at hand you can later show why a decision was made the way it was.
- What if the supplier does not send a new version?
- The supplier only has to send the new version on their own initiative to those who bought the product in the twelve months before the revision. If you buy a product less often, ask for the current SDS yourself. See also: how old can an SDS be?
- What if only the date or the address changed?
- Record the new version and note that the content was compared. The risk assessment, the card and the label do not need adjusting, because the information they are based on has not changed.
Read more
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