Does a product approval still hold after the SDS is revised?
Summary
Only if the revised safety data sheet leaves composition, hazard classification and the properties your approval relied on unchanged; otherwise re-check just the parts the revision touches. A revision date by itself decides nothing. The verdict depends on which sections changed and why, so read the revision note or compare both versions before the next order ships.
A revised EU safety data sheet must show "Revision: (date)" on the first page and point out the changes in section 16, unless they are indicated elsewhere (Regulation (EU) 2020/878, Annex II, 2020).
US preparers must add significant new hazard information to a safety data sheet within three months and provide the update with the first shipment after it (OSHA 29 CFR 1910.1200, 2026).
EU suppliers that update the sheet for new hazard or risk management information, an authorisation or a restriction must send it to every recipient supplied in the preceding 12 months (REACH Article 31 paragraph 9, consolidated 2026).
In Canada, a sale within 90 days of significant new data may use the current sheet plus a dated document listing the required changes (Hazardous Products Regulations section 5.12, as amended 2022).
When does a product approval still hold after an SDS revision?
A product approval still holds after a safety data sheet revision when the revision touches nothing the approval was based on: not the composition, not the hazard classification and not a property your approval tested or specified. The condition table below decides, section by section, whether the approval holds, needs a partial re-check or needs a full re-evaluation.
Revised SDS section | Verdict | Why |
|---|---|---|
Version number, formatting or wording only (section 16) | Holds; file the new version | No property, constituent or hazard changed |
Section 1, supplier name, address or emergency contact | Unconfirmed until the supplier confirms the manufacturer and manufacturing site are unchanged | A new site or legal entity can fall under the approval or a change-notification clause |
Section 2, hazard classification | Partial re-check of labels, storage and handling; full re-evaluation if the approval required a hazard class | The approval may rest on the product not carrying that hazard class |
Section 3, composition (new substance, CAS number or range) | Full re-evaluation | Performance and compatibility were proven on the old composition |
Section 8, exposure limits or protective equipment | Partial re-check of workplace controls | Product performance is unaffected, use conditions change |
Section 9, physical and chemical properties | Partial re-check of the properties the approval used; full re-evaluation if one moved outside its limit | Flash point, density or pH may be approval criteria |
Section 14, transport | Partial re-check of shipping and storage | Product approval holds, logistics may not |
Revision note missing or unclear | Unconfirmed; approval conditional until the supplier explains | No basis to keep or withdraw it |
The row that decides most cases is section 3: a composition change means the old approval was proven on a different product, so it needs a full re-evaluation. A wording-only revision, by contrast, leaves the approval in force once the new version is filed. An unchanged section 3 does not prove the formula is unchanged, because it must list only ingredients classified as health hazards, and usually only above their cut-off limits (OSHA 29 CFR 1910.1200 Appendix D, 2026); ask the supplier whether the product was reformulated.
Which SDS revisions affect an existing product approval?
The safety data sheet revisions that affect an existing product approval are the ones that touch its basis: composition, classification, or a property your approval tested. Write that basis down first, as a list of the specific findings the approval rested on, such as a test result, a restricted-substance check or a flash point limit.
Read why the revision happened. In the EU, suppliers must update the sheet without delay when new information on hazards or risk management measures becomes available, once an authorisation has been granted or refused, and once a restriction has been imposed (REACH Article 31 paragraph 9, consolidated 2026). A revision triggered by a restriction or new hazard information is more likely to reach a restricted-substance check or a hazard class than one that only updates an address.
In the US, a revision may carry significant new information on hazards or on ways to protect against them, which the preparer must add within three months (OSHA 29 CFR 1910.1200(g)(5), 2026). In Canada, significant new data means data that change a hazard classification or the ways to protect against the hazard (Hazardous Products Regulations section 5.12, as amended 2022). Either kind of change reaches the approval only where the approval relied on that hazard or protection.
How do you find what changed between two SDS versions?
You find what changed between two safety data sheet versions by reading the revision indication first, then comparing sections 2, 3, 8, 9 and 14 side by side against the version your approval used. The date of last revision appears in section 16 under US rules (OSHA 29 CFR 1910.1200 Appendix D, 2026), and a date shows only that something changed, not what.
EU rules give you more to work with. A revised sheet must identify "Revision: (date)" on the first page together with an indication of which version it replaces, and section 16 must give "a clear indication of where changes have been made to the previous version" unless that indication appears elsewhere (Regulation (EU) 2020/878, Annex II, 2020). The same text requires the supplier to be able to explain the changes on request.
Keep the version your approval used. EU actors must keep the information needed for their REACH duties for at least 10 years after they last supplied or used the substance or mixture (REACH Article 36, consolidated 2026). Without the old version, a side-by-side comparison is impossible, and every section stays unconfirmed until the supplier states what changed.
What should you do when an SDS revision touches the product approval?
When a safety data sheet revision touches the product approval, re-evaluate only the findings the confirmed changes reach, keep every other finding as it stands, and list each item still to confirm. A full re-approval of everything wastes time, and a blanket "still approved" hides the change.
Mark each finding in the approval as unchanged, re-check or unconfirmed, using the condition table.
Ask the supplier in writing: what changed and why, whether the product was reformulated, from which lot or batch the change applies, and whether the technical data sheet or specification also changed.
Re-run only the tests and checks behind the re-check findings, against the original approval limits.
Hold the approval as conditional while any item is unconfirmed, and record who confirms it and by when.
Lubinpla handles a revised safety data sheet in a reorder review by re-evaluating only the scope that confirmed changes and unconfirmed items touch, keeping the other findings, and listing the re-check items that remain, with your approval at each step.
Frequently asked questions
Does a supplier have to send you the revised SDS?
It depends on the jurisdiction. EU suppliers must send a revision made for new hazard or risk management information, an authorisation or a restriction, free of charge, to recipients supplied in the preceding 12 months (REACH Article 31 paragraph 9, consolidated 2026). US manufacturers and importers must provide it with the first shipment after the update (OSHA 29 CFR 1910.1200(g)(6), 2026). In Canada there is no requirement to send it to past purchasers (CCOHS, 2026).
Is a new revision date alone a reason to re-approve a product?
No. A revision date shows that the sheet changed, not what changed or whether the change reaches your approval. Read the revision note, compare the sections your approval relied on, and re-approve only if one of them changed.
Should you keep using the product while the SDS change is unconfirmed?
Keep using it only under the conditions the revised sheet sets for handling, storage and protection, since those reflect the supplier's current information. Treat performance and composition-based findings as conditional until the supplier confirms what changed, and record that decision with a date and an owner.