When Must a Safety Data Sheet Be Updated?

Imperium SDS guides · 2026-08-23

A safety data sheet is a snapshot of what was known about a product on the day it was authored. Products get reformulated, toxicology gets published, regulatory lists grow, and suppliers revise their own sheets — so every SDS has a shelf life. The question is not whether yours will need updating, but whether you will notice when it does. This guide covers the events that legally trigger an update, the specific rules in the major jurisdictions, one persistent myth about Canada, and the housekeeping practices that keep a document library defensible.

What triggers an update

Four categories of change account for nearly all required revisions:

• New hazard information. A new toxicology study, an updated classification from a data provider, a reclassification of an ingredient, or new information about protective measures. This is the trigger the regulations are written around.
• Composition or formulation changes. A reformulated product is, for SDS purposes, a different product: mixture classification, ingredient disclosure in Section 3, exposure limits in Section 8, and transport data can all shift. Even a "drop-in" raw-material substitution deserves a reclassification check.
• Regulatory-list changes. Section 15 cites lists that move on their own: California Proposition 65 adds chemicals over time, the EU SVHC Candidate List is updated periodically (historically a couple of times a year), EU harmonised classifications gain entries with each adaptation of CLP Annex VI, and exposure-limit tables get revised. None of these change your product — but they change what a compliant sheet for it says.
• Supplier data changes. If a raw-material supplier issues a revised SDS with a stricter classification or new hazard data for an ingredient you use, that is new hazard information about your mixture, and it flows downstream into your own sheet.

The rules you can rely on

United States — three months

OSHA's Hazard Communication Standard, 29 CFR 1910.1200(g)(5), requires that when the manufacturer, importer, or employer preparing the SDS becomes newly aware of significant information regarding a chemical's hazards, or ways to protect against them, that information must be added to the SDS within three months. Labels must be updated within six months under the parallel labeling provision. Note what the rule does not say: there is no fixed expiry date on a US SDS. A sheet with no new information can remain valid indefinitely — though, as discussed below, treating that as a reason never to look at it is poor practice.

European Union — without delay, and to recent recipients

REACH (Article 31 and Annex II) requires suppliers to update the SDS without delay when new information that may affect risk-management measures or new hazard information becomes available, and when relevant regulatory changes occur — an authorisation being granted or refused, or a restriction being imposed. Distinctively, the updated version must then be provided, dated and marked as revised, to every recipient supplied within the preceding 12 months. An EU update is therefore a distribution event, not just an editing event — you need records of who received the product recently. SVHC Candidate List additions are a common practical trigger, since a listed ingredient above 0.1% w/w creates communication obligations of its own.

Canada — update on new data, not every three years

This is where the most persistent SDS myth lives. Under the old WHMIS 1988 regime (the Controlled Products Regulations), an MSDS expired after three years and had to be reissued even if nothing had changed. That rule is gone. WHMIS 2015, under the Hazardous Products Act and Hazardous Products Regulations, replaced it with an obligation to keep the SDS accurate and up to date as of every sale or importation: when a supplier becomes aware of significant new data about the product, the SDS must be updated within the prescribed period (90 days is the timeline in the Act for sale; verify current requirements for your situation with Health Canada). If you still have a procedure that reissues Canadian sheets on a fixed three-year clock "because WHMIS requires it," the requirement it cites no longer exists — though a periodic review of that general shape remains a reasonable voluntary practice.

Other jurisdictions

Most GHS-adopting countries follow the same pattern — update when significant new information arises, with jurisdiction-specific timelines and distribution duties. Where you sell into a market not covered above, verify current requirements rather than assuming the US or EU rule applies. Our jurisdiction comparison guide covers what else differs between these regimes.

Best practices beyond the legal minimum

Date and number every revision

Every issued SDS should carry an issue or revision date (Section 16, and in the EU also on the first page) and a revision number, with a brief note of what changed in the revision. "Revision 4 — updated Section 8 exposure limits; Section 15 Prop 65 listing added" tells a downstream reader and a future auditor exactly what happened. A sheet with no date is effectively unusable for compliance purposes: no one can tell whether it predates a relevant change.

Run a periodic review cycle anyway

"No fixed expiry" is not the same as "no review needed." The failure mode of trigger-based updating is silent: you only update when you become aware of new information, and awareness is exactly what an unmonitored document library lacks. Many companies therefore review every SDS on a fixed cycle — commonly every one to three years — checking ingredient classifications, exposure limits, and regulatory lists against current sources even without a known trigger. The review often concludes "no change needed," and documenting that conclusion is itself valuable: it converts "we never looked" into "we looked and confirmed."

Watch the lists, not just the product

Composition changes announce themselves inside your own company; regulatory-list changes do not. Someone — or something — should be monitoring Prop 65 additions, SVHC Candidate List updates, Annex VI adaptations, and exposure-limit revisions against your ingredient set. This is a place where authoring software earns its keep: Imperium SDS, for example, tracks the freshness of its regulatory datasets and screens compositions against them, so a list change surfaces as a flagged sheet rather than a surprise in an audit.

Keep superseded versions

When you issue revision 5, revision 4 does not get deleted — it gets archived. Superseded SDSs document what hazard information was communicated at the time of past shipments, which matters for exposure records, incident investigations, and litigation. (In the US, OSHA's exposure-records rule requires employers to preserve certain exposure-related records for decades; retaining old SDSs is the conventional way suppliers and employers alike preserve that history.) Archive with dates intact and mark them clearly as superseded so no one ships one by accident.

Close the loop downstream

An updated sheet sitting on your server helps no one. Push revisions to active customers — the EU makes the 12-month look-back mandatory, but it is good practice everywhere — and make sure your own incoming supplier SDSs are versioned and dated on receipt, so you can detect when an ingredient sheet you rely on has quietly changed. If you are revising sections as part of an update, our section-by-section authoring guide covers what belongs where.

This guide is general educational information, not legal or regulatory advice. Requirements vary by jurisdiction and change over time — always have safety data sheets reviewed by a qualified person before use. See our Terms of Service.

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