EU Classification Labeling and Packaging (CLP) Guidelines require online sellers of chemical products to present any warning statements for those products to the consumer so that they can make an informed buying decision. Specifically, Article 48(2) of the EU CLP Regulation provides that “any advertisement for a mixture classified as hazardous or covered by Article 25(6) which allows a member of the general public to conclude a contract for purchase without first having sight of the label shall mention the type or types of hazard indicated on the label”. The European Chemicals Agency (ECHA) has also provided additional guidance under FAQ 0273 that states, “The type of hazard is best specified by providing the relevant hazard statements, including the supplemental hazard statements as referred to in CLP Article 25(6). It is also recommended that the hazard pictograms and signal word are mentioned, where appropriate, to alert the reader to a potential hazard.”
For this purpose, Amazon has created a mechanism to display any applicable hazards statements on product detail page. For your product to be sold in compliance, you need to provide Amazon with a Safety Data Sheet (SDS) for each hazardous good product that you are selling, from which we will extract the required data.
Before submitting an SDS, please make sure it complies with the below standards:
1. The SDS is for the listed product.
2. Check with the manufacturer to make sure you have the most recent SDS (SDSs older than 5 years will not be accepted)
3. Make sure that the SDS includes all 16 standard SDS sections
4. For more information, check the link: https://echa.europa.eu/-/guidance-on-the-compilation-of-safety-data-sheets
What are the ASINs I need to provide a SDS for?
You are required to provide a SDS if you are listing hazardous goods for sale on Amazon, subject to exceptions below. You are the most appropriate person to know what hazardous goods you are selling. Hazardous goods are chemical products that, due to their composition, present possible hazards for use or storage. They can range from household products to industrial chemicals, including but not limited to: cleaning agents, or products containing cleaning agents, paints, aerosols, air fresheners, glues, automotive agents, some building materials, gardening chemicals, lab reagents, etc. For more information on hazardous goods, please see point 2 below.
2. How to identify a potential hazardous good?
An easy way to identify a product that may be in scope of the CLP Regulation is to check its European label for GHS pictograms (red framed white diamonds) or hazard phrases. In case of doubt, please contact your supplier or manufacturer. You can also check guidelines here: https://echa.europa.eu/documents/10162/23036412/clp_introductory_de.pdf/a3c5627d-032a-4d6b-9fa9-4fc6b260dc57
3. Am I required to provide a SDS for all chemical ASINs?
There are several categories of products that don’t require a SDS, as defined by CLP Article 1, and these include cosmetics, medicinal products, veterinary medicinal products, food, feeding stuff, medical devices and articles. For more information, check the link: https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32008R1272&from=EN
4. What if I’m not able to identify the products that may be possible hazardous goods?
If you don’t provide the appropriate document (SDS), Amazon will not be able to identify your product with the right hazard phrases and pictograms, therefore your product is at risk of being listed non-compliantly. Please note that Authorities may require Amazon to take down non-compliant listings.