Using SDS to Support REACH / Proposition 65 Declarations

Question: Is a Safety Data Sheet (SDS) for one of my products declares 0.0 – 0.1 percent lead in the “Composition” section sufficient to support declarations made under REACH and Proposition 65?

Answer: Because the product in question is an alloy (homogeneous substance), the SDS should be sufficient as supporting documentation for a REACH SVHC declaration, so long as all substances have been reported. However, in the case of Proposition 65, percentage composition is not sufficient to determine exposure during foreseeable use which is the determining factor for if the product would require a warning labeling.

The percentage, if the SDS is representing one material, would be sufficient to determine if REACH SVHC threshold may be triggered for Article 33 requirements. For Proposition 65, the recipient of the SDS would need to determine if their use and the percentage of lead would trigger a warning requirement.

This content is accurate as of May 24, 2019.

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