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SDS Authoring Services for EU, GHS and Turkish Markets

Safety data sheets written to EU REACH Annex II and CLP, OSHA HazCom and other GHS formats, and Turkey's KKDIK Annex 2. Mixture classification, multilingual versions, extended SDS and controlled updates.

What this covers

  • New SDSs and revisions to REACH Annex II, as amended by 2020/878
  • Mixture classification under CLP, GHS and Turkey's SEA regulation
  • Turkish SDSs prepared by a certified KDU under KKDIK
  • Extended SDS with exposure scenario annexes
  • Multilingual sets built from one master classification
  • Version control, change logs and update triggers
On this page
  1. SDS authoring services for manufacturers, formulators and importers
  2. What SDS authoring involves
  3. Which rules your SDS has to meet
  4. The 16 sections and where the work is
  5. Classification of mixtures
  6. New EU hazard classes and the SDS updates due from 2025 to 2028
  7. Extended SDS with exposure scenarios
  8. Multilingual SDS
  9. Updates and version control
  10. How an SDS project runs
  11. What we need from you
  12. What you receive
  13. What affects cost and turnaround
  14. Why use a Turkey-based SDS team
  15. Related chemicals compliance services

SDS authoring services for manufacturers, formulators and importers

Our SDS authoring services cover new safety data sheets, revisions and translations for the EU, Great Britain, Turkey, the United States and other GHS markets. We classify the substance or mixture, write all 16 sections to the format each jurisdiction requires, and keep the versions under control as regulations and data change. Turkish SDSs are prepared and signed by a certified Chemical Assessment Expert (KDU), as KKDIK requires.

What SDS authoring involves

SDS authoring is the work of classifying a chemical product, deciding which hazard and precautionary information applies, and writing a safety data sheet in the 16-section format required by the target market. It covers composition, classification, exposure controls, physical and toxicological data, transport and regulatory sections, and keeping the sheet current.

A good SDS is consistent with the label, the registration dossier and the transport classification. Most SDS problems we see come from mismatches between these: a hazard statement on the label that is missing in section 2, an occupational exposure limit from the wrong country in section 8, or a UN number that does not match the classification in section 14.

Which rules your SDS has to meet

The 16-section structure comes from the UN Globally Harmonized System (GHS), but each jurisdiction adopts it with its own content rules, language requirements and author qualifications.

MarketLegal basisPoints that often trip exporters
European UnionArticle 31 and Annex II of REACH (EC) No 1907/2006, as amended by Regulation (EU) 2020/878; classification under CLP (EC) No 1272/2008Official language of each Member State where supplied; nanoform, endocrine disrupting properties, specific concentration limits, M-factors and ATEs now required in sections 2, 3, 9, 11 and 12
Great BritainUK REACH and GB CLPMandatory GB classification list differs from EU Annex VI over time; UK supplier details in section 1
TurkeyArticle 27 and Annex 2 of KKDIK; SEA regulation for classificationMust be in Turkish, prepared by a KDU certified under KKDIK Annex 18, and uploaded to the Ministry's SDS notification system
United StatesOSHA Hazard Communication Standard, 29 CFR 1910.1200, as revised in 2024Environmental hazard classes are not mandatory; HazCom 2024 compliance date for mixtures is 19 November 2027 for manufacturers, importers and distributors
Other GHS marketsNational GHS implementationsEach country picks its own GHS revision and building blocks, so cut-off values and categories differ

For Turkey, the 2014 SDS regulation was repealed with effect from 31 December 2023. Since then only KKDIK Annex 2 applies, and only a KDU may prepare the sheet. Our Turkish SDS under KKDIK page explains what that means for foreign suppliers.

The 16 sections and where the work is

Every SDS has the same headings. The effort is concentrated in a few of them.

SectionContentWhat we check most closely
1. IdentificationProduct identifier, uses, supplier, emergency phoneRegistration numbers, UFI where applicable, local emergency number
2. Hazards identificationClassification, label elements, other hazardsConsistency with the label, PBT and endocrine disruption statements
3. CompositionHazardous ingredients and their classificationConcentration ranges, specific concentration limits, M-factors, ATEs
4 to 7First aid, firefighting, accidental release, handling and storageAdvice that fits the actual hazards rather than generic text
8. Exposure controlsOccupational exposure limits, DNELs, PNECs, PPECountry-specific limit values, glove material and breakthrough time
9. Physical and chemical propertiesAppearance, flash point, pH, vapour pressure and so onMeasured data rather than literature values for mixtures
10. Stability and reactivityReactivity, incompatible materials, decomposition productsConsistency with sections 7 and 9
11 and 12. Toxicological and ecological informationHealth and environmental effectsData source per endpoint, calculation basis for mixtures
13. DisposalWaste treatment methodsWaste codes appropriate to the market
14. TransportUN number, shipping name, class, packing groupADR, IMDG and IATA alignment, marine pollutant status
15. Regulatory informationSpecific national and EU provisionsAuthorisation, restriction, SVHC and Seveso categories
16. Other informationRevision details, abbreviations, full hazard statementsChange indicators, and for Turkey the KDU's name, certificate number and date

Classification of mixtures

For a mixture, classification is the core of the job. Under CLP, and under Turkey's SEA regulation which mirrors it, a mixture is classified in this order of preference.

  1. Test data on the mixture itself, where valid. This is the usual route for physical hazards such as flammability, and sometimes for skin and eye irritation using in vitro methods.
  2. Bridging principles, where a similar tested mixture exists: dilution, batching, concentration of highly hazardous mixtures, interpolation, substantially similar mixtures and aerosols.
  3. Calculation from the ingredients, using the additivity formulas for acute toxicity (ATE mix), the summation method for corrosion, irritation and aquatic hazards, and generic or specific concentration limits for the remaining classes.

The quality of the result depends on the ingredient data. We collect supplier SDSs for every component, check them against harmonised classifications in CLP Annex VI and the C&L Inventory, and query suppliers where the data is incomplete. M-factors for aquatic toxicity and specific concentration limits are two places where small ingredient errors change the classification of the whole mixture.

The same formulation can be classified differently in different markets. The US does not apply environmental hazard classes as mandatory. Some GHS countries still use older revisions or include acute toxicity Category 5. For a product sold in several regions, we keep one master data set and derive each classification from it, so that differences are deliberate and documented.

New EU hazard classes and the SDS updates due from 2025 to 2028

Commission Delegated Regulation (EU) 2023/707 added hazard classes for endocrine disruption (human health and environment), PBT and vPvB, and PMT and vPvM. The transitional dates for classification and labelling are staggered.

ProductPlaced on the market fromAlready on the market before that date
Substances1 May 2025Must comply by 1 November 2026
Mixtures1 May 2026Must comply by 1 May 2028

The revision of CLP itself, Regulation (EU) 2024/2865, has applied in large part since 1 July 2026. Its new label formatting rules, such as minimum font sizes, were postponed in late 2025 and now apply from 1 January 2028. When a substance in your portfolio gains a new classification, every mixture that contains it needs a classification review and, in most cases, a revised SDS.

Extended SDS with exposure scenarios

When a substance is registered under REACH at 10 tonnes or more per year and is classified as hazardous or PBT or vPvB, the registrant prepares a chemical safety report. The relevant exposure scenarios must then be annexed to the SDS. The result is called an extended SDS, or eSDS.

We prepare exposure scenario annexes from the registrant's chemical safety report, using the use descriptor system (sector of use, product category, process category, environmental release category) and the conditions of use that keep exposure below the DNELs and PNECs. For formulators, we help you check whether your customers' uses are covered, and convert the information from several substance-level scenarios into safe use information for the mixture. KKDIK has the same mechanism in Article 27(7), so Turkish registrants at 10 tonnes or more face the same task.

Multilingual SDS

REACH requires the SDS in the official language of each Member State where the product is supplied, unless that Member State provides otherwise. Turkey requires Turkish under Article 27(5) of KKDIK. A product sold across Europe and Turkey can need more than 20 language versions.

We separate the technical content from the language work. The classification and section content are fixed in one master version, and translations are then produced with consistent standard phrases for hazard and precautionary statements in each language. This keeps all versions on the same revision number and avoids the common problem of a translated SDS that is two revisions behind the English one.

Updates and version control

An SDS must be updated without delay when new hazard information becomes available that affects risk management, when an authorisation is granted or refused, or when a restriction is imposed. Updated versions must be sent free of charge to every recipient supplied in the previous 12 months. KKDIK uses the same triggers and the same 12 month rule.

Other common triggers are changes to harmonised classifications through CLP adaptations to technical progress, new occupational exposure limits, transport regulation changes, a new registration number, and formulation changes. We keep a change log for each SDS, mark revised sections, and can monitor your portfolio against regulatory changes so that you know which sheets are affected before customers ask.

How an SDS project runs

  1. Portfolio review, 1 week. We list products, markets and languages, and identify which sheets need new authoring, revision or translation only.
  2. Data collection, 1 to 3 weeks. Formulations, raw material SDSs, test reports and transport data. Ingredient data gaps are raised with you at this stage.
  3. Classification, 1 to 2 weeks. We classify each product for each target market and send you a classification summary for approval before writing.
  4. Authoring, 1 to 3 weeks. The 16 sections are written in the master language, with label elements for your label artwork.
  5. Translation and local versions, 1 to 2 weeks. Language versions and country-specific sections 8 and 15.
  6. Delivery and maintenance. Final PDFs, editable files where agreed, change log, and ongoing update monitoring if you choose it.

A single SDS for a simple mixture with complete ingredient data can be turned around within a few working days.

What we need from you

  • Full formulation with CAS numbers and exact or narrow concentration ranges, including impurities and additives.
  • Current SDSs for every raw material, preferably in English and no older than their latest revision.
  • Any test reports on the mixture, such as flash point, pH, viscosity, or in vitro irritation tests.
  • Uses, packaging sizes and the markets and languages required.
  • Transport classification if you already ship the product, and your emergency telephone arrangements.
  • For extended SDSs, the exposure scenarios received from your suppliers or your own chemical safety report.

What you receive

For each product you receive the SDS in each required language, a classification report showing the method and data behind each hazard class, label elements ready for artwork, and a revision record. For Turkey, the SDS carries the KDU details required in section 16 and can be uploaded to the Ministry's SDS notification system in the Integrated Environmental Information System.

What affects cost and turnaround

The number of products and languages matters, but these factors usually decide the effort: the complexity of the formulation, the quality of raw material SDSs, whether mixture test data exists, the number of target markets with different classifications, and whether exposure scenarios have to be integrated. Product families with shared base formulations can be authored together, which lowers the cost per sheet.

Why use a Turkey-based SDS team

We work from İzmir, Ankara and Kocaeli, and chemicals management (SDS, KKDIK and SEVESO) has been part of our environmental consulting work for more than 20 years. For EU and international suppliers this gives two practical advantages. The Turkish SDS, which legally needs a certified KDU, comes from the same team that writes your EU and GHS versions, so classifications and revision numbers stay in step. And when a Turkish customer or inspector questions a sheet, we deal with it directly in Turkish and report back to you in English.

SDS work is often the first step into Turkey for EU and Asian chemical suppliers. If your substances are imported into Turkey at 1 tonne or more per year, they also need KKDIK registration, and the Turkish SDS has to carry the registration number once it is issued. Our article on SDS requirements in Turkey covers the Turkish rules in more detail.

Specialist services in SDS Authoring

Turkish SDS (KKDIK)

Turkish safety data sheets written to KKDIK Annex 2 and signed by a certified Chemical Assessment Expert (KDU). For foreign suppliers whose Turkish customers need a compliant SDS, a matching label and the registration number.

Learn more

Questions

SDS Authoring questions

How long does SDS authoring take?

A single SDS for a mixture with complete raw material data usually takes a few working days. Larger portfolios run in batches over several weeks. Most delays come from missing or outdated ingredient SDSs, so we check the data set first and tell you what is missing before classification starts.

Can you convert our EU SDS into a US or Turkish SDS?

Yes, but it is not a straight translation. The US OSHA format uses different classification building blocks and section 15 content, and a Turkish SDS must follow KKDIK Annex 2, cite Turkish regulations and be prepared by a certified KDU. We reuse the technical data and re-check classification for each market.

Who is responsible for the content of an SDS we commission?

The supplier placing the product on the market remains legally responsible for the SDS. We take professional responsibility for the classification and writing based on the data you provide, and we document the data sources. In Turkey the certified KDU who prepares the SDS is also named in section 16.

When must an SDS be updated?

Without delay when new hazard information affects risk management, when an authorisation is granted or refused, or when a restriction applies. In practice, harmonised classification changes, new exposure limits, formulation changes and new registration numbers also trigger updates. Recipients supplied in the previous 12 months must receive the new version free of charge.

Do mixtures that are not classified as hazardous need an SDS?

Not automatically. Under REACH and KKDIK an SDS must be provided on request if a non-classified mixture contains, above set thresholds, a substance hazardous to health or the environment, certain CMR, sensitising, PBT or SVHC substances, or a substance with a workplace exposure limit. Many customers ask for one regardless.

What is an extended SDS?

It is an SDS with exposure scenarios attached as an annex. It applies where a registrant had to prepare a chemical safety report, typically for hazardous substances registered at 10 tonnes or more per year. The scenarios describe the operational conditions and risk management measures that make each identified use safe.

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SDS Requirements in Turkey Under KKDIK, a Guide for Suppliers

Turkey requires safety data sheets in Turkish, written to KKDIK Annex 2 by a certified KDU and uploaded to the Ministry. When an SDS is needed, what it must contain, and common errors.

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