TL;DR:
ECHA’s EU-wide enforcement project examined over 2,500 safety data sheets across 28 countries and found 35% were non-compliant. 30% of companies were referred for enforcement. With CLP new hazard classes mandatory by November 2026, PFAS restrictions covering 10,000+ substances heading for EU legislation in 2027, and REACH enforcement intensifying, EU chemical companies face overlapping deadlines that manual SDS processes cannot address.
ECHA’s enforcement project (REF-11) was the most comprehensive SDS quality examination across Europe. Inspectors in 28 countries reviewed 2,500+ SDSs. The headline: 35% were non-compliant.
| Metric | Finding | Source |
| 35% | SDSs non-compliant across 28 EU-EEA countries | ECHA REF-11 / KFT |
| 30% | Companies referred for enforcement | ECHA eval stats 2025 |
| 313 | Compliance checks in 2024 | ECHA eval stats |
| 34% | High-volume dossiers reviewed | ECHA eval stats |
| 1/3 | Imported mixtures failed REACH |
ECHA Enforcement Forum |
| 15,500 | Total registrations checked since 2009 | ECHA eval stats |
| KEY TAKEAWAY |
| 35% non-compliant across 28 countries. 30% enforcement referrals. Intensifying import checks. SDS quality gaps carry real consequences. |
Outdated classifications: When CLP Annex VI is updated — 22 new + 10 revised substances in the latest update — every affected SDS must be recalculated.
Incomplete content: EU REACH SDS requirements specify precise content for 16 sections, including exposure scenarios. Cloud platforms use the Cefic ESCom package (1,600+ phrases) to automate this.
Distribution gaps: Without automated tracking, companies cannot prove current versions were delivered.
| KEY TAKEAWAY |
| Non-compliance results from outdated classifications, incomplete content, and untracked distribution. Each gap is structural. |
313 compliance checks in 2024, 208 data requests, 30% referred for enforcement. Referral to national authorities is formal enforcement — fines, market access restrictions, or product withdrawal. For 100+ tonnes/year chemicals, 34% of dossiers are now reviewed.
One-third of imported mixtures failed REACH requirements. Customs cooperation is intensifying.
| KEY TAKEAWAY |
| Compliance check → data request → enforcement referral. 34% of high-volume dossiers reviewed. Import checks intensifying. |
| Deadline | Applies To | SDS Impact |
| May 2025 (now) | New substances | Classify for ED, PBT/vPvB, PMT/vPvM |
| May 2026 | New mixtures | New mixture SDSs must include new hazard data |
| Nov 2026 | Existing substances | Portfolio-wide SDS update + label regeneration |
| End 2026 | PFAS evaluation | Scientific basis for 10,000+ substance restriction |
| Early 2027 | EU PFAS vote |
Mass recalculation + redistribution |
| May 2028 | Existing mixtures | Final wave — every SDS, label, language |
| KEY TAKEAWAY |
| Six overlapping deadlines 2025–2028. November 2026 CLP and 2027 PFAS are the two highest-impact milestones. |
The proposed EU-wide PFAS restriction covers 10,000+ substances across 14 sectors. ECHA evaluation concludes end 2026. For companies managing manually, weeks of work per restriction. Cloud platforms automate the cascade.
| KEY TAKEAWAY |
| PFAS restrictions will trigger mass portfolio updates. Cloud handles this through mass recalculation. Manual processes face weeks per event. |
A €122M+ coatings manufacturer centralized on one cloud SDS platform: 500,000 items in 25 minutes across 15,000+ products and 50+ countries.
A chemical importer: 25%+ faster, under a week. A textile chemicals company: 25-year partnership, cloud upgrade. A building materials company: master system for SAP/Oracle data exchange.
| KEY TAKEAWAY |
| One pattern: centralized, automated cloud SDS. Fragmented manual processes cannot keep pace with overlapping deadlines. |
Audit SDS compliance. Map portfolio against CLP November 2026 deadlines. Assess PFAS exposure. Cloud SDS platforms address all three. Standard implementation: 5 business days.
| KEY TAKEAWAY |
| Audit now, map CLP deadlines, assess PFAS. Cloud SDS platforms address all three in 5 business days. |
35% Failed ECHA’s Check. How Would Yours Score?
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