When importing sunscreen into regulated markets like the US, EU, or Australia, a complete and compliant Safety Data Sheet (SDS, formerly MSDS) is not just a paperwork step—it’s the foundation for safe handling, regulatory clearance, and downstream customer trust. This guide outlines the 16 mandatory sections of an SDS under GHS and ISO standards, plus what importers should confirm and request from their manufacturer before shipment.
Understanding the 16 Sections of a Sunscreen SDS
The Global Harmonization System (GHS) specifies a uniform SDS structure, which applies to sunscreen as a cosmetic or OTC product depending on market classification. Here’s the breakdown:
- Identification: Product name, relevant uses, supplier details.
- Hazard(s) identification: GHS classification, label elements, hazard statements.
- Composition/Information on ingredients: INCI list, CAS numbers, concentration ranges for hazardous components.
- First-aid measures: Specific treatments for exposure routes (skin, eye, ingestion).
- Fire-fighting measures: Suitable extinguishing media, hazards from combustion.
- Accidental release measures: Spill response, PPE recommendations.
- Handling and storage: Safe practices, conditions to avoid.
- Exposure controls / personal protection: Engineering controls, PPE specs.
- Physical and chemical properties: Appearance, odor, pH, melting/freezing point, viscosity.
- Stability and reactivity: Conditions to avoid, incompatible materials.
- Toxicological information: Routes of exposure, symptoms, acute/chronic effects.
- Ecological information: Environmental impact, biodegradability.
- Disposal considerations: Waste treatment, disposal methods.
- Transport information: UN number, transport hazard class, packing group.
- Regulatory information: Applicable laws and regulations by market.
- Other information: SDS preparation/revision date, key references.
What Importers Should Request Before Shipment
- Full SDS (current revision) in English and the target market’s language.
- Composition breakdown including INCI and percentages for claim substantiation and regulatory screening.
- Evidence of hazard classification per GHS or local rules.
- Stability and compatibility data for primary packaging formats.
- Microbiological test reports aligned to shelf-life and contamination standards.
- Regulatory cross-check indicating any restricted or banned ingredients in target market.
- Batch-specific COA confirming congruence with SDS composition.
Small SDS Review Checklist
| Section |
Importer Review Focus |
| Identification |
Ensure brand/INCI alignment with product label |
| Hazard Classification |
Verify no incorrect hazard codes assigned |
| Composition |
Check ingredient names against regulatory lists |
| Handling & Storage |
Evaluate for realistic supply chain conditions |
| Transport |
Confirm sunscreen is non-DG unless aerosol |
Why SDS Accuracy Matters for Sunscreen
- Ensures compliance with customs inspections.
- Protects against misclassification penalties.
- Supports retailer onboarding in regulated channels.
- Provides employee and customer safety information.
FAQ
Is an SDS mandatory for all sunscreens?
In most markets, yes—especially if the sunscreen is classified as an OTC or contains hazardous preservatives or aerosol propellants. Even non-hazardous cosmetic products require an SDS for workplace safety compliance.
Can I use the supplier’s SDS without changes?
You can, but it must accurately reflect your branded product’s formulation, packaging, and hazard information. Always verify alignment before submission to authorities.
How often should the SDS be updated?
Generally every 3–5 years, or immediately when the formula, supplier, or applicable regulation changes.
What if the SDS lists a banned ingredient for my market?
Do not proceed with import. Request reformulation or source an alternative supplier that meets ingredient standards.
Do SDS requirements differ across markets?
Core structure is harmonized via GHS, but specific classification thresholds and language requirements differ—check local regulations for nuance.
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Hi, I'm Alex Zong, hope you like this blog post.
With more than 20 years of experience in OEM/ODM/Private Label Cosmetics, I'd love to share valuable knowledge related to cosmetics & skincare products from a top-tier Chinese supplier's perspective.