- What are the advantages of communication regarding chemicals in products?
- What are the legal requirements?
- Poison centre notification (PCN)
- Who are the actors in the supply chain?
- How to communicate with suppliers
- Who is entitled to ask for critical safety information?
- You have questions or needs regarding the compliance of supplied information, e.g., an updated SDS is needed.
- You may need additional information about a product that is already used, e.g., regarding the purity of a substance or the composition of a supplied mixture.
- You want to phase out a supplier's substance or mixture, and you want to discuss whether it offers alternatives that are less harmful and have a similar function.
- You need a new input material and contact a supplier in order to obtain information and potentially also samples for testing the product in your production.
- You want to agree on a long-term supply contract potentially including conditions about the purity of substances or the content of hazardous chemicals in any mixtures you intend to purchase.
- How to verify/validate received information
- How to plan chemical analyses
- Environmental claims and ecolabels
- Third-party certified ecolabels
- What are digital solutions in chemical communication?
- Why do digital solutions matter?
- Worldwide digital data systems
- Step-by-step
- More resources
How to communicate throughout the supply chain?
Effective supply chain communication ensures that chemical safety information is available to all actors to ensure that chemical risks can be appropriately managed. Information on hazards and risk related to the use of a mixture is an integral part of the product.
Chemicals risk management relies not only on good communication within the company but also up and down the supply chain. This does not only apply to legally required communication, but also to all additional efforts implemented to facilitate safe use, substitution and/or compliance of downstream users.
When it comes to ensuring compliance, communication regarding the content of input materials with suppliers and customers is essential. You should know the composition of your product, because ignorance (due to missing communication) does not prevent legal consequences in the event of non-compliance.
What are the advantages of communication regarding chemicals in products?
What are the legal requirements?
SDS
The requirements for communicating about chemicals – substances and mixtures – in the form of an SDS are defined in the REACH regulation:
- The SDS must be compiled in accordance with REACH Annex II and provided in the language of the Member State where the chemical is placed on the market;
- An SDS must be provided at the request of the customer for all classified substances and mixtures.
Safety Data Sheets are critical communication tools that provide formulators, article producers, service providers and emergency responders with life-saving hazard information throughout the supply chain.
Information and SDSs can be used for different purposes:
- Worker safety: the information in the SDS must be accessible to workers and serve to prevent accidents;
- Environmental management: check compliance with limit values / emission reduction measures;
- Transportation: give key details (UN numbers, hazard classes, emergency measures) for safe and compliant transportation of hazardous materials;
- Emergency response: guiding medical personnel, firefighters and spill responders during incidents;
- Training: used in employee hazard communication and training programmes;
- Risk management: support risk assessments, safe work procedures and regulatory compliance;
- Consistency: a standardised format ensures that information is understood consistently throughout industries and countries.
CLP Product Labelling
Labels on chemical products in the European Union (EU), are defined by the CLP Regulation (Classification, Labelling and Packaging).
Classified substances and mixtures must be labelled, indicating the main hazards and protective measures. Furthermore, the design of packages and the information that must be provided on them is defined in legislation.
This system ensures that chemical hazards are communicated clearly and in a standardised way via CLP pictograms, H – hazard statements. In addition, protection measures are communicated with P – precautionary statements.
| CLP Pictograms | H Statements(Hazard Statements) | P Statements(Precautionary Statements) |
| These are standardised symbols used to clearly signify the type of hazard that a chemical presents. There are 9 types of hazard pictograms, each framed in a red diamond. | These describe the nature and severity of the hazard.Physical hazards (e.g., H200 series)Health hazards (e.g., H300 series)Environmental hazards (e.g., H400 series) | These advise on preventive, response, storage and disposal measures. |
Poison centre notification (PCN)
Standardised information on mixture composition and hazards must be submitted to the Poison Information Centre (PCN) in relation to mixtures that are supplied to the general public and are harmful to human health, while the use of authorised substances must be notified to the ECHA within three months.
The notification is provided using a specific format. A Unique Formula Identifier is assigned to the mixture (UFI) and placed on the product label. This number links the specific product/mixture to the notified information (including toxicological data). Including the UFI number in the SDS is voluntary and recommended. The notification dossier is prepared using the IUCLID format, an internationally harmonised data format for chemicals, and should be submitted online via the ECHA Submission Portal. This requirement is binding from 1 January 2025 for all mixtures falling within the scope of Annex VIII of the CLP Regulation.
National obligations may require reporting the use and quantities of Substances of Very High Concern (SVHCs).
According to REACH, the use of authorised substances must be notified to the European Chemicals Agency within 3 months of the commencement of the use of the substance in question. More information on how to submit a notification is provided on the ECHAs website.
Further national communication obligations may exist, e.g., regarding whether SVHCs are used, and in what amounts (cf. Overview of Legislation).
Who are the actors in the supply chain?
Data exchange among chemical supply chain actors is important because it:
- Enhances safety by providing critical information for safe handling, transport, and use of chemicals;
- Reduces risks to human health and the environment through proper management of hazardous materials;
- Supports sustainability by enabling material tracking, impact assessment, and informed substitution with safer alternatives;
- Promotes circularity by helping recyclers to recover valuable materials and minimise resource waste.
How to communicate with suppliers
Communicators in companies should be trained and know about chemicals and chemical risks. Information providers should be aware of their customers’ needs for information, information recipients should ensure that information suppliers know why they need specific information and not ask for any information that is not needed. In many cases, standardised communication, e.g., exchanging compliance declarations is insufficient.
Clear contact structure
- One contact person per supplier;
- Request a contact person from the supplier;
- Appoint one designated contact person per organisation.
Competent communication – useful for both the company and the supplier
- Ensure that the request has a clear purpose;
- Explain the background of requests;
Document supplier experience – supports future decisions
- Keep notes in the supplier database or inventory;
- Track repeated SDS requests and incompetent contacts;
Reasons to contact suppliers
- Legal compliance (e.g., updated SDSs);
- Product details (purity, composition);
- Alternatives for harmful substances;
- New input materials & testing;
- Long-term contracts with specific requirements.
Verify supplier information
- Check SDS quality, especially from new suppliers;
Quality assurance of input materials
- Specify purity or banned substances;
- Perform random chemical analyses;
- Verify product compliance.
Who is entitled to ask for critical safety information?
You have questions or needs regarding the compliance of supplied information, e.g., an updated SDS is needed.
In this case, the supplier is legally required to provide the information you require and if it fails to do so, you should consider changing the supplier.
You may need additional information about a product that is already used, e.g., regarding the purity of a substance or the composition of a supplied mixture.
The supplier is not obliged to answer, but should do so in order to build trust and keep you as a customer. If this information is important to you and the supplier fails to provide you with the information you require, you should consider changing the supplier.
You want to phase out a supplier’s substance or mixture, and you want to discuss whether it offers alternatives that are less harmful and have a similar function.
In this case, the supplier should answer your enquiries in order to keep you as a customer; assess if there are any attempts to convince you to keep using the original product and consider your reaction to such behaviour.
You need a new input material and contact a supplier in order to obtain information and potentially also samples for testing the product in your production.
You may build on existing relations if you already know the supplier or establish new ones. In either case, suppliers should be open and take time to communicate with you.
You want to agree on a long-term supply contract potentially including conditions about the purity of substances or the content of hazardous chemicals in any mixtures you intend to purchase.
Such contracts could also include requirements stipulating verification that conditions such as purity or content are fulfilled, e.g., by chemical analyses.
The information provided by the supplier should be checked, especially if the supplier is new and you do not have experience with the quality of information it provides. Check the quality of the SDSs you receive and look for information from alternative sources, such as the ECHA’s database on registered substances or from other suppliers. The quality of the legally required information is a good indicator of the trustworthiness of the supplier and the quality of the product alike.
If you request substances of a particular purity or define lists of substances which must not be contained in the mixtures you purchase from a supplier, you might consider conducting a few random chemical analyses to test whether the products are compliant or not.
How to verify/validate received information
Laboratory analyses can be a good procedure to check supplier information if you have any doubts and/or wish to obtain additional information on chemicals in the raw materials purchased. It may also be necessary or useful to generate information on the company’s own product to check compliance or to provide proof of compliance to customers.
Depending on the scope of the analysis and its purpose, different analytical techniques and methods are used, for example chromatography or spectrometry to identify and quantify the content of substances.
When you select a laboratory, ensure that it operates in compliance with good laboratory practice so the results will be widely accepted. Lists of accredited laboratories may be available from the national or regional accreditation bodies. At EU level, NANDO will be a useful contact.
Reasons to analyse or test input material or the company’s own product may include:
- quantification of substances in input materials, e.g., to check information from suppliers;
- identification of potential contamination with unwanted substances in input materials;
- assessing certain performance parameters of chemicals/ products;
- classification of physical-chemicals properties;
- documentation of compliance for customers, e.g., the absence of (a list of) restricted substances to underpin a declaration of conformity;
- defining the share of volatile organic compounds in a product.
How to plan chemical analyses
Start by defining the purpose and scope of any measurement and carefully select the parameters that would answer open questions. Analyses for compliance purposes are normally very clear in this regard. Experienced laboratories can provide competent support. Consider how often a measurement is needed, i.e. tests for classification have to be performed only once, whereas analysis for quality control purposes should be undertaken regularly.
Environmental claims and ecolabels
Environmental claims and ecolabels help to communicate the environmental benefits of products to consumers and businesses. They come in three main types with different levels of verification and transparency.
Third-party certified ecolabels
- Awarded by independent organisations;
- Use public, standardised criteria (including chemicals);
- Require formal application and verification;
- Ecolabels signal high environmental performance.
Self-declared environmental claims
- Created by the manufacturer;
- Must be accurate, verifiable and non-misleading;
- Supporting data should be publicly accessible;
- Claims like “BPA-free” can be misleading if harmful alternatives are used;
- Should align with the Green Claims Directive.
Environmental Product Declarations (EPDs)
- Follow the ISO 14025:2006 standard;
- Based on Life-Cycle Assessment (LCA);
- Provide quantitative impact data;
- Targeted to business-to-business communication.
Third-party certified ecolabels
The EU Ecolabel is the official European environmental label for non-food products and services.
The Nordic Swan Ecolabel is an official sustainability label used in the Nordic countries.
The Blue Angel has been the ecolabel of the German Federal Government for over 45 years.
What are digital solutions in chemical communication?
Modern tools that digitise and centralise chemical safety and compliance data to improve accessibility and communication throughout the supply chain.
Why do digital solutions matter?
QR codes:
- Embedded on product labels, linking directly to real-time SDSs, declarations or instructions.
Example: A logistics worker scans a QR code on a pallet to instantly access the latest transport classification and storage guidance.
Product passports:
- Digital records providing comprehensive information about each product’s origin, materials, environmental impact, and disposal recommendations. Example:
- A battery product with a product passport enables users to verify its composition, performance (e.g., capacity and state of health), and safe handling and recycling methods.
- A paint product with a product passport allows contractors to verify VOC levels, chemical hazards and safe disposal methods.
Database integration:
- Connects internal systems with customer, regulatory or public databases, ensuring seamless updates and consistency across platforms.
Example: An SDS management system auto-updates customer portals when a formulation or regulation changes.
Worldwide digital data systems
The International Material Data System (IMDS)
- A global online database for automotive manufacturers;
- Enables suppliers to report material composition for adherence to international regulations such as REACH and RoHS, helping manufacturers to assess environmental and health impacts;
- Promotes transparency throughout the automotive supply chain, facilitates substance risk analysis, and supports sustainability goals.
Step-by-step
SDS Compliance Review
Assess the implementation of legal requirements regarding communication and ensure that your company provides good, up-to-date SDSs for all products that require one;
Communication Roles and Routines
Identify current routines, responsibilities and experiences of communicating with suppliers, customers, consumers and authorities;
Internal Communication Evaluation
Evaluate past communication with staff having implemented the communication:
- Are there any internal guidelines? Are they implemented? Is that useful and what has proved not to work well?
- What are the main lessons from communicating with suppliers? Is information obtained? What can be learned from suppliers about do’s and don’ts in customer communication?
- What are the main lessons from communicating with customers? What questions are being asked? Is any feedback obtained regarding the information provided? How efficient is the provision of information to customers?
- How does cooperation work within the company to support the communicators in the purchasing and in the sales department?
Supply Chain Communication Improvement
Identify improvement options for communication up and down the supply chain and implement them.
You may consider including communication goals in the company’s chemicals policy to increase the importance of safety information and ensure that sufficient resources are made available, especially for the compilation of good SDSs.
More resources
Communication in the supply chain
The ECHA Communication in the Supply Chain page explains how effective information exchange between all actors—including manufacturers, importers, and downstream users—is essential under the EU REACH regulation to ensure the safe use of chemicals. The site also presents practical tools and harmonised approaches (e.g., use of maps, exposure scenarios, and templates) that support consistent communication throughout the supply chain and help to improve chemical safety and regulatory compliance.
Communication with suppliers
Sample template and building blocks for supply contracts
Template provide suggestions of what could be included in supply contracts regarding chemicals.
Checklist for the Safety Data Sheets
The safety data sheet (SDS) belongs to the chemical and should provide sufficient information for safe handling and use. It is vital for your chemical management that the information is correct and useful, and you should therefore ensure that it is of good quality. This simple checklist shows how you can judge quality.
Communication with customers
Sample template for a Declaration of Compliance
This template may be used to inform the customer about the conformity of your own products with either legal requirements or the customer’s requirements. A declaration of compliance should always be based on sound evidence.
Guidance on Poison Centre Notifications
Guidance on harmonised information relating to emergency health response – Annex VIII to CLP
Guidance to Regulation (EC) No 1272/2008 on classification, labelling and packaging (CLP) of substances and mixtures aims to assist users in complying with their obligations under the CLP Regulation.
This manual provides practical guidance to support industry with their poison centre notification (PCN) obligations according to Article 45 and Annex VIII to the CLP Regulation1. In particular how information can be prepared and submitted to the Member States Appointed Bodies, e.g., through the ECHA Submission portal.
The ECHA UFI Generator (Create UFI) page is an official online tool that enables companies to generate a Unique Formula Identifier (UFI) — a 16-character code used to identify hazardous chemical mixtures placed on the EU market.
UFI Generator application: User Guide
The UFI User Guide (ECHA) explains how companies can generate, assign, and manage Unique Formula Identifiers (UFIs) to comply with EU chemical safety rules under the CLP Regulation. It provides step-by-step instructions for creating single or multiple UFIs, validating them, and linking each code to a specific chemical mixture composition.
Testing and analyses
The OECD Guidelines for the Testing of Chemicals are a unique tool for assessing the potential effects of chemicals on human health and the environment. Accepted internationally as standard methods for safety testing, the Guidelines are used by professionals in industry, academia and government involved in the testing and assessment of chemicals (industrial chemicals, pesticides, personal care products, etc.).
Database of accredited bodies for testing the safety of toys in the EU (NANDO)
The NANDO database contains the names and details of notified bodies performing conformity assessments for the purposes of the Toy Safety Directive 2009/48/EC.
The Global Ecolabelling Network (GEN) website presents a leading international non-profit organisation that brings together trusted ecolabelling programs worldwide to promote credible environmental standards. It supports consumers, businesses, and governments in making sustainable purchasing decisions by providing reliable, lifecycle-based certification and helping to prevent greenwashing.
Communication with consumers
Use of environmental claims: best practice guide
This guide focuses on how to develop clear and substantiated self-declared environmental claims avoiding misleading information. In addition, it introduces other types of environ mental claims: ecolabel schemes and environ mental product declarations.
The Guidelines for Providing Product Sustainability Information
Global guidance on making effective environmental, social and economic claims, to empower and enable consumer choice. The Guidelines offer clear guidance to value chain and public sector professionals on making effective, trustworthy claims to consumers, and in regard to product-related sustainability information.