Safety Data Sheet Translation: REACH Compliance and Multilingual SDS Requirements

Key Takeaways

• Safety data sheets (SDS) for chemical substances and mixtures supplied in the EU must be provided in the official language or languages of the member state where the substance or mixture is supplied — this is a legal requirement under REACH Regulation (EC) No 1907/2006.
• UK REACH imposes the same language requirement for SDS distributed in Great Britain — SDS for the UK market must be in English.
• An SDS has 16 mandatory sections covering identification, hazard classification, composition, first aid measures, fire-fighting measures, handling and storage, exposure controls, physical and chemical properties, and disposal. All 16 sections must be accurately translated.
• SDS translation errors create both regulatory compliance failures and direct worker safety risks — incorrect first aid instructions, wrong PPE guidance, or inaccurate hazard classifications have operational consequences.
• GHS (Globally Harmonized System) hazard and precautionary statements (H and P statements) have standardised official translations in each EU language — these must be used exactly as published, not retranslated independently.

Safety data sheets are among the most legally prescribed documents in manufacturing, chemical supply, and industrial operations. Their content, format, and language requirements are governed by regulation — not by commercial preference — and getting the translation wrong has consequences that go beyond a compliance audit finding. This guide covers the SDS translation obligations under REACH and UK REACH, what must appear in each language version, and what accurate SDS translation requires.

What is a safety data sheet?

A safety data sheet (SDS) — formerly called a material safety data sheet (MSDS) — is a standardised document that provides information about the hazards, safe handling, storage, and disposal of a chemical substance or mixture. SDS are produced by manufacturers, importers, and distributors of chemical substances and mixtures, and are supplied to downstream users in the supply chain.

The SDS format is standardised globally under the GHS (Globally Harmonized System of Classification and Labelling of Chemicals), developed by the United Nations. In the EU, GHS is implemented through CLP Regulation (EC) No 1272/2008 (Classification, Labelling and Packaging). In the UK, it is implemented through UK CLP.

REACH Regulation (EC) No 1907/2006 governs the registration, evaluation, authorisation, and restriction of chemicals in the EU. Article 31 of REACH sets out the obligation to provide an SDS, and Annex II specifies the requirements for the preparation of SDS — including format, content, and language.

REACH language requirements for SDS

Article 31(5) of REACH requires that the SDS be supplied in an official language or languages of the member state where the substance or mixture is placed on the market, unless the member state concerned provides otherwise.

In practice, this means:

• An SDS for a substance supplied in Germany must be in German
• An SDS for a substance supplied in France must be in French
• An SDS for a substance supplied in Poland must be in Polish
• An SDS for a substance supplied across multiple EU member states requires separate language versions for each

There is no provision for a single multilingual SDS to substitute for language-specific versions. A German-language SDS cannot be supplied to a French customer in lieu of a French-language version.

The obligation falls on the supplier — the entity that supplies the substance or mixture to the downstream user. UK manufacturers exporting chemical substances or mixtures to EU markets must provide SDS in the appropriate EU language for each market supplied.

UK REACH language requirements

Following Brexit, UK REACH is the domestic equivalent of EU REACH in Great Britain. Under UK REACH, SDS for substances and mixtures supplied in Great Britain must be in English. Separate English-language SDS are required for the UK market; EU-language versions do not satisfy UK REACH requirements.

Northern Ireland continues to follow EU REACH requirements under the Windsor Framework arrangements.

The 16 sections of an SDS: translation scope

REACH Annex II specifies 16 mandatory sections for an SDS. All 16 must be accurately translated in each language version. The sections are:

1. Identification of the substance or mixture and of the supplier
2. Hazard identification
3. Composition and information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls and personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

Each section contains specific mandatory content. Sections 4 (first aid), 5 (fire-fighting), 6 (accidental release), and 8 (exposure controls and PPE) are particularly safety-critical — translation errors in these sections have direct implications for the safety of workers who handle the substance.

GHS H and P statements: standardised translations

Hazard statements (H statements) and precautionary statements (P statements) are standardised phrases used in GHS hazard communication. Each statement has a code (e.g. H302: Harmful if swallowed; P260: Do not breathe dust/fume/gas/mist/vapours/spray) and an officially translated version in each EU official language.

These official translations are published by the European Chemicals Agency (ECHA) and must be used exactly as published — they cannot be independently translated or paraphrased. An SDS that uses a non-standard translation of an H or P statement, even if the meaning is equivalent, does not comply with REACH Annex II requirements.

This is a specific requirement that distinguishes SDS translation from general technical translation. An SDS translator must apply the ECHA-published H and P statement translations for each target language, cross-referenced against the correct statement codes, rather than producing an independent translation of the statement text.

Exposure limits and occupational exposure values

Section 8 of the SDS covers exposure controls and personal protection. Occupational exposure limits (OELs) for substances must be stated for the country where the SDS is used. EU member states have different national OELs for many substances — the EU sets indicative occupational exposure limit values (IOELVs) as a minimum, but member states may set more stringent national limits.

A German-language SDS must state the German workplace exposure limits (AGW values). A French-language SDS must state the French valeurs limites d'exposition professionnelle (VLEP). These are not translated values — they are country-specific regulatory values that must be researched and inserted into the appropriate language version of the SDS.

Experienced SDS translators maintain current national OEL databases for each market covered — this is not something a general technical translator without SDS-specific expertise can reliably provide.

Transport information in SDS

Section 14 of the SDS covers transport information under the international transport regulations: ADR (road), RID (rail), IMDG (sea), and IATA (air). Transport classification codes, UN numbers, proper shipping names, and packing group designations are internationally standardised and appear identically in all language versions of the SDS.

However, the proper shipping name — the official name of the substance for transport purposes — must appear in the language of the SDS. Proper shipping names are defined in the relevant transport regulation and must be used exactly as specified, not independently translated.

Keeping SDS current

REACH Annex II specifies that an SDS must be updated without delay when new information becomes available that may affect risk management measures, or when an authorisation has been granted or refused or a restriction has been imposed. Updated SDS must be supplied to all downstream users to whom the substance or mixture has been supplied in the preceding 12 months.

For manufacturers supplying across multiple EU markets, this means updating SDS in every required language when substance classifications change, exposure limits are revised, or new hazard information becomes available. Translation memory, combined with a version-controlled SDS management process, ensures that only changed content requires retranslation — unchanged sections are applied from the memory at no additional cost.

Global LTS provides manufacturing translation services for safety data sheets across all EU official languages and English, with translators experienced in REACH Annex II requirements and ECHA H and P statement conventions. Contact us to discuss your SDS translation requirements.

For related reading, see our guides on IATF 16949 and ISO 9001 translation and CE marking translation requirements.