The short answer is yes, if you have supplied the substance or mixture to them in the last 12 months.
Or in other words, if it has passed more than 12 months from the last supply, you are no longer obliged to provided an updated SDS to those customers.
Where does this obligation come from, you might ask?
It is from Article 31(9) of Regulation (EC) no 1907/2006 (»REACH regulation«) which requires suppliers to update the SDS without delay and to provide it to all recipients of the substance or mixture to whom they have supplied it within the preceding 12 months.
Is it enough if I say to the customer the updated SDS can be found on our webpage?
No. You have to actually deliver the direct link, or file (electronically) or on paper to the customer.
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