Understanding when these documents are required, and why they matter, helps brands, suppliers, and distributors navigate the complex requirements of cosmetic product compliance.
Safety Data Sheets: essential for substances and mixtures
A Safety Data Sheet (SDS) is a legally required document for any substance or mixture classified as hazardous under the EU and UK CLP (Classification, Labelling and Packaging) Regulations, or under REACH.
While most finished cosmetic products are not classified as hazardous — and therefore do not require an SDS when sold to consumers — the situation changes upstream in the supply chain.
SDS authoring is mandatory for:
- Raw materials and cosmetic ingredients:
- A substance is classified as hazardous under the CLP Regulation.
- A substance is identified as persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB), according to the criteria in Annex XIII of REACH.
- A substance is included in the candidate list of substances subject to authorisation.
- Mixtures that are not classified as hazardous but contain certain hazardous components (such as fragrance blends for instance):
- ≥ 1% of a substance hazardous to health or the environment
- ≥ 0.1% of a sensitiser, carcinogen, mutagen, or reproductive toxin
- Mixtures such as Intermediate products or bulk formulas classified as hazardous under the CLP Regulation.
- Any cosmetic product that meets CLP hazard criteria (for example, certain hair dyes, nail products, or alcohol-based sprays)
The SDS ensures that all handlers — from manufacturers to logistics providers — have access to clear, standardised safety information. This includes details on composition, hazard identification, handling, storage, transport, and emergency measures.
Even when not legally required, many companies find they need to provide an SDS to transport products and materials to demonstrate there is no hazard and also to provide handling instructions. In this case, in theory, the SDS does not have to meet the strict requirements on the format / content but by doing so this helps the recipients access the information needed.
Slightly different requirements are present as the UK REACH and GB CLP apply in England, Scotland, Wales, while EU REACH/CLP applies in Northern Ireland and the EU. For the EU national language requirements will apply, particularly if the material is being shipped or handled in that country.
IFRA Certificates: fragrance safety and compliance
An IFRA Certificate confirms that a fragrance complies with the safety standards established by the International Fragrance Association (IFRA). These standards set maximum permitted concentrations for fragrance materials across 12 defined product categories — from rinse-off skincare to fine fragrance and home care.
While an IFRA Certificate is not a legal requirement under cosmetics legislation, it is widely recognised as an industry best practice and is frequently requested by regulatory bodies, safety assessors, and brand owners as part of the Product Information File (PIF).
IFRA documentation is recommended for:
- All fragrance products like EDT’s
- Any raw material, essential oil blend, or perfume compound supplied to cosmetic manufacturers
- Safety assessments, where fragrance concentration and category data must be verified
For companies creating custom blends of essential oils, it is advisable to check IFRA levels during the formulation stage. This ensures that fragrance allergens and restricted materials remain within permitted limits — avoiding reformulation later and ensuring the product can pass safety assessment without delay.
Documentation as part of responsible distribution
Both SDS and IFRA Certificates are key components of the compliance documentation package that supports responsible trade across the cosmetics supply chain. While the SDS focuses on the safe handling of chemical substances, IFRA certification assures consumer safety and product integrity through fragrance control.
Together, they provide transparency, traceability, and confidence to all stakeholders — from ingredient suppliers to finished product brands.
About The Cosmetic Experts
The Cosmetic Experts is a cosmetic consultancy specialising also in regulatory documentation and compliance support. The company provides expert authoring of Safety Data Sheets (SDS), IFRA Certificates, and CLP-compliant labels, helping brands, manufacturers, and distributors meet EU, UK, and global safety requirements efficiently and accurately.
Website: www.thecosmeticexperts.co.uk Press contact: info@thecosmeticexperts.co.uk
