Guide
Safety data sheets and CLP labels
Sell a bottle of perfume to a person and you need no safety data sheet at all. Sell the same juice by the kilo to a candle maker and you are a supplier of a chemical mixture, with everything that follows from it.
Checked against the sources named at the foot of this page on 13 August 2026.
When you need one, and when you genuinely do not
This is the question that wastes the most time in home fragrance and indie perfumery, usually because somebody has been told an answer that was correct about a different situation.
Who you are selling to decides it
A finished perfume, to a person
No sheet
In the EU and Great Britain a cosmetic supplied to the end user is outside the duty. The cosmetics regime covers it instead.
A concentrate, to another business
A sheet
You are supplying a mixture to somebody who will process it further. Sixteen sections, and a CLP label if it is classified.
Anything, into the United States
Ask again
A consumer cosmetic is outside the workplace rules for consumer use. The same product used at work is not, so the answer turns on who handles it.
A customer asking for a sheet is not always a customer entitled to one, and supplying a bad sheet is worse than explaining why none is required. A customer who will process your product further is entitled, and should be given one.
One thing worth saying plainly to anybody selling fragrance oils on a marketplace: the moment you sell by the kilo to a candle maker or a soap maker, you are a supplier of a chemical mixture. That is a change of legal identity rather than a change of product, and it brings classification, a label and a sheet with it.
The sixteen sections, in the order the regulation sets
The headings, their numbering and their order are prescribed. They may not be reworded, merged or rearranged, and a sheet that does any of those is not a safety data sheet. Since 2021 the EU format is the one set by Regulation (EU) 2020/878.
| No. | Section | What it carries |
|---|---|---|
| 1 | Identification | The product, its uses, you, and an emergency telephone number. The unique formula identifier goes here where there is one. |
| 2 | Hazard identification | The classification, and the label elements that follow from it. |
| 3 | Composition | Every hazardous constituent with its identifiers, its concentration and its own classification. Not the whole formula: the hazardous part of it. |
| 4 | First aid | By route of exposure, and what a doctor needs to know. |
| 5 | Firefighting | Suitable media, and what burning it produces. |
| 6 | Accidental release | Containment, cleanup, and keeping it out of drains. |
| 7 | Handling and storage | Including incompatibilities and the conditions it needs. |
| 8 | Exposure controls | Occupational limits where they exist, and the protective equipment. |
| 9 | Physical and chemical properties | Appearance, odor, density, flash point and the rest of the listed set. |
| 10 | Stability and reactivity | What it is incompatible with and what it decomposes into. |
| 11 | Toxicological information | By endpoint: acute, irritation, sensitization and the rest. |
| 12 | Ecological information | Aquatic toxicity, degradability, and the persistence assessment. |
| 13 | Disposal | Of the product and of the packaging. |
| 14 | Transport | UN number, proper shipping name, class and packing group. Most alcoholic perfume is a flammable liquid. |
| 15 | Regulatory information | What else applies to it, which for a fragrance is where the restrictions live. |
| 16 | Other information | The full text of every statement code used above, and the revision history. |
One habit is worth more than any of the individual sections: where something is not established, say so rather than leaving the line empty. A blank on a safety data sheet reads as nothing to declare, which is a claim, and usually not the one that was meant.
Where the classification comes from
Section 2 is the one everything else hangs off, and it is not a matter of opinion. It comes from one of two places.
- A harmonized entry. For substances that have one, the classification is mandatory and you may not substitute your own judgment for it. Great Britain keeps its own list, which began as a copy of the EU's and has not tracked it since, so the same substance can be classified differently in the two markets.
- Your own classification. For everything else, the supplier classifies against the criteria. For a mixture, it is calculated from what is in it and at what concentration.
That second point is the one that catches people out. Your fragrance supplier's data is the starting point and not the answer, because the classification of your product depends on your own dilution of theirs. The same oil at 6 percent in one product and 20 percent in another can land on opposite sides of a threshold, and only the calculation on your actual formula settles it.
Two classifications turn up in fragrance more than any others: skin sensitization, and hazardous to the aquatic environment. Neither is exotic and both reach a great deal of ordinary work.
What goes on a CLP label
Where the mixture is classified, the label carries a defined set and the elements are not optional or rearrangeable.
The elements, on one label
The codes are references, not label text: what goes on the label is the full sentence each one stands for. A sensitizing mixture below the classification threshold may still need a statement saying it contains a sensitizer, which is a separate trigger that catches a lot of home fragrance.
Poison centers, and the identifier on the label
A hazardous mixture placed on the EU market has to be notified to the bodies that answer emergency calls, so that somebody advising a doctor at three in the morning can look up what is actually in the bottle. The notification gets a unique formula identifier, and that identifier goes on the label, which is how the two are tied together.
Great Britain did not adopt that system and has no equivalent, so a GB label carries no such identifier and a GB sheet does not have a line for one. It is one of the clearest divergences between the two regimes and it is visible on the packaging.
A sheet is a living document
It is dated and versioned, and it has to be revised when something changes: the formula, the classification of an ingredient, a harmonized entry, or the regulation itself. Anybody you supplied in the preceding year has to be given the updated version, which means knowing who they were.
It also has to be supplied in the language of the country it is sold into, free of charge, and by the time the product is first delivered rather than on request afterward.
How Orris Bench handles this
The safety data sheet is generated from the same record the formula lives in, with the sixteen sections in the order the regulation prescribes, because that order is not an editorial choice. Which market a product is for is a fact you state once, and the sheet is written to that market's profile rather than to whichever regime the software met first.
Classification is calculated from the formula rather than copied off a supplier's document, which is the only way to get a mixture right, and the CLP label is produced from the same result. Where a section cannot be filled, it says what is not established rather than leaving the line blank, on the same principle the compliance checks follow: a gap stated is a gap somebody can close, and a gap left silent reads as nothing to declare.
Sources
The sixteen sections and their order are Annex II to Regulation (EC) No 1907/2006 (REACH) as replaced by Commission Regulation (EU) 2020/878. Classification and labeling are Regulation (EC) No 1272/2008 (CLP) and, for Great Britain, its retained equivalent with the GB mandatory classification list in place of Annex VI. Poison center notification and the unique formula identifier are Annex VIII to CLP. The position that a finished cosmetic supplied to a consumer needs no safety data sheet follows from REACH Article 2(6)(b). This page is written for people who make fragrances and it is not legal advice; whether your particular mixture is classified as hazardous is a calculation on your own formula.
Common questions
Does a perfume need a safety data sheet?
A finished cosmetic supplied to a consumer does not, in the EU or in Great Britain. REACH disapplies the title its safety data sheet duty lives in for cosmetics at the point of sale to the end user. What does need one is a mixture supplied to another business: a concentrate sold to a candle or soap maker, a base sold on, anything going to somebody who will process it further. The United States is different again, because a workplace sheet can be required there even where a consumer product would not need one.
What are the sixteen sections of a safety data sheet?
Identification; hazard identification; composition; first aid; firefighting; accidental release; handling and storage; exposure controls; physical and chemical properties; stability and reactivity; toxicological information; ecological information; disposal; transport; regulatory information; other information. The headings, their numbering and their order are prescribed and may not be reworded or rearranged. Since 2021 the EU format is the one set by Regulation (EU) 2020/878.
What has to go on a CLP label?
The supplier's name, address and telephone number; the nominal quantity; the product identifier; the hazard pictograms; the signal word, which is Danger or Warning; the hazard statements; the precautionary statements; and the names of the substances that caused the classification. Where the mixture is notified to poison centers, the unique formula identifier goes on it too.
Where does the classification come from?
For substances with a harmonized entry it is mandatory and you may not substitute your own. For everything else the supplier classifies against the criteria, and for a mixture the classification is calculated from what is in it and at what concentration. That is why your fragrance supplier's data is a starting point rather than an answer: the classification of your finished product depends on your own dilution of theirs.