Reminder from DEKRA about end of transition period on January 1, 2023

Time is Running Out to Update Safety Data Sheets

Oct 04, 2022

Experts from DEKRA have warned that manufacturers, importers, and formulators of chemical products need to update their safety data sheets without delay. The changes to Sections 1, 2, 3, and 9 according to EU Regulation No. 2020/878 will come into force in just three months’ time and will be binding from January 1, 2023. The supervisory authorities have already announced that they will be conducting corresponding checks.

According to DEKRA, the changes to the thresholds above which substances need to be listed in Section 3 are particularly important. These relate to certain hazards, for example substances which sensitize the skin or respiratory tract, or which are toxic to reproduction. Almost all the thresholds have been reduced to 10 percent of the original values, meaning that new substances will likely need to be listed in many safety data sheets.
Section 9 has been amended in line with the requirements of GHS Rev. 6 and 7. In addition to the properties stated in sub-section 9.1, other physical and chemical parameters now need to be indicated in 9.2 if their indication is relevant for the safe use of the substance or mixture. If there is a risk of explosive dust/air mixtures occurring, these include the lower explosive limit (LEL), minimum ignition energy (MIE), deflagration index KSt, and maximum explosion pressure pmax. These values can be determined in DEKRA’s laboratories if required.
When updating the safety data sheets, DEKRA also recommends checking whether the substances in the formulation are affected by the 39 new or 17 changed classifications pursuant to the 18th ATP (Adaption to Technical Progress), such as bisphenol A or melamine.
The authorities have announced a wide-ranging, Europe-wide monitoring campaign for 2023, which is why DEKRA’s experts are advising all manufacturers, importers, and formulators of chemical products to update their safety data sheets accordingly. Please note that the product labels must match the information stated in the safety data sheet.