A Safety Data Sheet (SDS) is often mandatory when importing or exporting certain products. This includes batteries, chemicals, cosmetics, oils, and other products that require certain precautions during storage and transportation.
Further, Safety Data Sheets are required by Amazon when selling products classified as Hazmat or Dangerous goods.
We Help Brands & Importers With Product Compliance (US & EU)
- Book a free consultation call today with Ivan Malloci to learn how we can help you with:
- Product Requirements Lists
- Product Certification
- Product & Packaging Labeling
- Lab Testing
What is the Safety Data Sheet (SDS)?
A Safety Data Sheet (SDS) is a standardized product safety document, which provides detailed instructions on how to safely handle, label, and store certain products.
Here are some items which must be included in an SDS:
- Product name
- First-aid instructions
- Protective equipment
- Safety storage instructions
Which products require an SDS?
An SDS may be required if you’re importing products classified as dangerous goods, which are also referred to by some (including Amazon) as Hazmat products.
Products that contain potentially hazardous chemicals, materials, or components are often classified as dangerous goods. Note that this is not limited to harmful chemicals and heavy metals, but also products that are essential to safety, such as car airbags.
Here are a few examples:
- Power banks
- Other products containing batteries
- Household cleaning products
- Auto parts
- Skincare products
- Essential oils
- Haircare products
- Petcare products
- Certain types of children’s products
As you can see in the list above, most products in contact with human skin or battery-powered devices require an SDS. That said, the requirements differ depending on whether your product is used in the workplace or in households.
Further, the product as a whole may be classified as dangerous goods if the device contains certain substances or materials (e.g. essential oils).
Why do I need a Safety Data Sheet (SDS)?
Safety Data Sheets are mandatory when importing certain products to the United States, the European Union, and other markets. Here are a few situations in which you can be requested to provide an SDS:
1. Freight forwarders may require an SDS before shipping your product
2. The customs authorities may require an SDS during the customs clearance process
3. Retailers and other customers may require that provide an SDS
4. Amazon requires an SDS when selling products classified as dangerous goods (Hazmat)
5. Market surveillance authorities may request an SDS
How do I get a Safety Data Sheet (SDS)?
In theory, you should receive the SDS from your manufacturer. That said, it’s often more complex than that.
Many contract manufacturers in China and other countries in Asia don’t know how to issue an SDS. Even if they do, they may not use the correct format and provide an accurate English language translation.
This is not because they are idiots, but simply because OEM manufacturers are not compliance experts. Virtually all established buyers either use a third party to get an SDS or instruct their supplier on how to create one.
It also depends on whether you’re importing factory-designed or custom-designed products.
Factories manufacturing certain commodities, such as wet wipes, often have standard SDS for various standard products.
However, this is less common among electronics or toy manufacturers producing custom-designed products based on buyer specifications.
An SDS cannot be issued for a custom-designed product that has not been made yet, and most suppliers expect the buyer to take care of the SDS and other documentation when products are manufactured according to the buyer’s specifications.
Using a Safety Datasheet (SDS) Authoring Service
In case your supplier cannot provide an SDS, your only option is to use a third-party Safety Datasheet (SDS) Authoring Service to do it for you.
That said, your supplier expects you to pay for it, either by increasing the unit price or asking you to pay the author service company directly.
How much does an SDS cost?
A Safety Data Sheet doesn’t cost you anything, as long as your supplier can provide one. However, if that’s not the case you’ll need to use an SDS authoring service.
The UL self-service SDS creation tool starts from USD 275 per SDS, while ‘done for you’ services can cost significantly more.
Do I need an SDS when selling on Amazon?
Amazon requires sellers of dangerous goods to provide a Safety Data Sheet (SDS) or an Exemption Sheet before listing their products on its platform.
This requirement is part of Amazon’s Dangerous Goods program, which permits sellers to list FBA-eligible dangerous goods. We explain the requirements below.
Products classified as dangerous goods by Amazon
Amazon provides examples of products that may be regulated as dangerous goods. We list a few of those products below.
- Apparel (e.g., hat stiffener)
- Consumer electronics (e.g., power banks)
- Beauty and personal care (e.g., perfume)
- Food and beverages (e.g., aromatic essential oils)
- Office (e.g., cartridges and toners)
- Sports and outdoor (e.g., lifesaving vests)
Amazon also categorizes various types of dangerous goods that can be sold via the FBA program:
Class 2 – Division 2.1 – Flammable gases
Class 2 – Division 2.2 – Non-flammable, non-toxic gases
Class 3 – Flammable liquids
Class 4 – Division 4.1 – Flammable solids
Class 5 – Division 5.1 – Oxidizers
Class 5 – Division 5.2 – Organic peroxides
Class 6 – Division 6.1 – Toxic substances
Class 8 – Corrosive substances
Class 9 – Miscellaneous dangerous substances – Lithium batteries
Class 9 – Miscellaneous dangerous substances – Magnetized material
You can find more examples of dangerous goods on Amazon Seller Central.
FBA Dangerous Goods program
Amazon’s FBA Dangerous Goods program allows participating sellers to list FBA-eligible dangerous goods on its platform. Sellers wishing to participate in the Dangerous Goods program should join its waitlist.
The program requires sellers of dangerous goods to comply with relevant documentation, labeling, and packaging requirements.
This also includes compliance with relevant federal or state regulations, such as the following:
a. PHMSA Regulations (relevant for ground transportation of dangerous goods)
b. FFA Regulations (relevant for air transportation of dangerous goods)
c. Hazardous Materials Regulations
d. Globally Harmonized System of Classification and Labelling of Chemicals
Sellers should submit items such as the following:
a. Safety Data Sheet (SDS) or Exemption Sheet
b. Test reports to prove compliance with relevant regulations
An SDS typically has 16 sections and requires the provision of product information such as the following:
- Control measures
- Emergency and first-aid procedures
- Physical and chemical properties
- Physical and health hazards
- Precautions for safe handling and use
- Routes of exposure
Some products may not require an SDS. In this case, Amazon might require the provision of an Exemption Sheet. This is the case for the following categories of products:
- Battery-powered products
- Products without harmful chemicals
Sellers of dangerous goods on Amazon might need to include the following information on their product or packaging label:
a. UN number (e.g., 1266)
b. Product weight in kilograms (e.g., 0.9 kg)
c. Product volume in milliliters for a gas or liquid (e.g., 59.1 ml)
d. Relevant GHS/CLP hazard pictograms
One example of a GHS/CLP hazard pictogram is that of a skull and crossbones for Class 6, Division 6.1 toxic substances.
Packaging and shipping requirements
Amazon also requires compliance with its FBA Dangerous Goods program’s terms and conditions regarding the shipping and packaging of dangerous goods (referred to as “Program Units”).
Participating sellers are required to adhere to the following requirements:
a. Avoid shipping Program Units via an Amazon Partnered Carrier
b. Avoid shipping Program Units together with other types of products
c. Only ship Program Units to designated Amazon fulfillment centers
d. Securely and commercially package Program Units in a manner compliant with relevant labeling, packaging, size, and weight requirements (e.g. Hazardous Materials Regulations)
What’s the difference between an SDS and MSDS?
The SDS is based on a standardized and internationally recognized format, while the older Material Safety Data Sheet (MSDS) could be made in different formats. As such, you’ll need an SDS and not an MSDS.
That said, some manufacturers and even freight forwarders often refer to the SDS as an MSDS.