I received this e-mail recently:
“Morning Luka
I read your articles which was very informative
I am struggling to compile a safety data sheet as the MSDS supplied for one of the raw materials has the corrosive and danger pictograms
The component is listed as ‘trade secret’
No information is given for this component under section 3.
Is this legal I could not find corrosive listed in your table”
This is one of the common challenges EU companies face, when importing raw materials from outside of EU.
Why? Because the rules for disclosing ingredients in Section 3 are not the same for everyone. In some regions (for example the US), suppliers are allowed to hide certain components by listing them as “trade secret”. This is possible under OSHA legislation.
But here’s the problem. If your raw material is classified as corrosive (or any other hazard), you still need enough information to compile a compliant EU Safety Data Sheet under REACH/CLP.
So, what can you do as an EU importer using such raw materials in your formulations? Here are three things that you might find useful:
- Start with your supplier. Many non-EU suppliers aren’t familiar with how strict REACH requirements are. A clear request often solves the issue.
- If they don’t want to disclose, consider testing. You may need to run your own analysis to determine the composition. That gives you the data, but it also adds cost.
- If testing isn’t worth it, consider changing the supplier. Sometimes the most practical solution is to find an alternative source that provides full Section 3 details so you can stay compliant without extra work.
Compliance is not just a list of check marks. Compliance is a competitive advantage. If you are facing similar challenges you can write to us at info@bens-consulting.eu. We will do our best to find the best solution for you.
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