An Aerosol Safety Data Sheet Has 16 Sections
A safety data sheet (SDS) is the 16-section document that the REACH Regulation requires for any substance or mixture classified as hazardous: it identifies the product and its supplier, describes its hazards and explains how to handle, store and transport it and what to do after an accident. An aerosol with a flammable propellant needs one, free of charge and in the local language, from the first delivery.
When Is a Safety Data Sheet Mandatory for an Aerosol?
According to the Spanish Ministry of Health, the supplier must provide the sheet when the product is classified as hazardous under CLP, when it is persistent, bioaccumulative and toxic, or when it contains a substance on the candidate list for authorisation. Since almost every aerosol with a hydrocarbon or DME propellant is classified as a flammable aerosol, the data sheet is the rule rather than the exception.
The INSST technical note NTP 1198 sets out the borderline cases:
| Situation | SDS required? |
|---|---|
| Mixture classified as hazardous | Yes, with the first delivery |
| Not classified, with ≥1 % hazardous substance | Only if a professional customer asks |
| Not classified, gaseous mixture | On request, from ≥0.2 % by volume |
| Sold to the public with enough information | No, unless a professional asks |
| Finished cosmetic | No, covered by its own regulation |
A spray deodorant needing no SDS under REACH does not mean it travels without paperwork: the carrier and the warehouse still need its classification for transport and storage.
What Sections Does a Safety Data Sheet Have?
The content is set by Annex II of REACH, replaced by Regulation (EU) 2020/878, mandatory for every data sheet since 1 January 2023. There are 16 fixed sections and no heading may be left blank; the length of the sheet is proportionate to the hazard of the product.
| Section | Content | What it covers for an aerosol |
|---|---|---|
| 1 | Identification and supplier | Brand, supplier, emergency phone number |
| 2 | Hazards identification | Aerosol category, H222 or H223, H229 |
| 3 | Composition | Hazardous components, propellant included |
| 4 | First aid | Inhalation, skin and eye contact |
| 5 | Firefighting | Risk of the can bursting when heated |
| 6 | Accidental release | Leaks, ventilation, ignition sources |
| 7 | Handling and storage | Out of the sun, below 50 ºC |
| 8 | Exposure controls | Exposure limits, protection |
| 9 | Physical and chemical properties | % by mass of flammable components |
| 10 | Stability and reactivity | Heat, incompatible materials |
| 11 | Toxicological information | Effects of the formula |
| 12 | Ecological information | Effects on the aquatic environment |
| 13 | Disposal | Containers with residual pressure |
| 14 | Transport | UN 1950, class 2 |
| 15 | Regulatory information | Rules that apply to the product |
| 16 | Other information | Revisions and changes |
What Are Safety Data Sheets Used For?
The data sheet is the risk assessment tool of whoever receives the product. Annex II itself requires it:
In particular, the safety data sheet shall enable employers to determine whether any hazardous chemical agents are present in the workplace and to assess any risk to the health and safety of workers arising from their use.
In practice it is read by the customer's health and safety officer, the warehouse (section 7), the carrier (section 14) and the emergency services (sections 4 to 6). That is why the butane or propane data sheet supplied by the gas vendor will not do: it describes only the propellant, while the aerosol's sheet must cover the whole mixture, formula and propellant together, in its pressurised container.
Who Writes the Data Sheet in Contract Manufacturing?
The obligation lies with the supplier placing the aerosol on the market, usually the brand, whose details appear in section 1. Annex II requires it to be written by a competent person with suitable training, and REACH requires it to be updated without delay when new information on hazards or risk management measures becomes available. The revised version carries the mention "Revision: (date)" and is sent free of charge to every customer who received the product in the previous 12 months.
In practice, the data sheet is prepared by whoever knows the formula. In Ilerspray's contract manufacturing it is part of the validation and regulatory stage, together with technical sheets and regulatory registration where required, and it is delivered with the product. If the aerosol is sold outside Spain, the data sheet is supplied in the official language of each destination country, as Article 31 of REACH requires.
💡 Technical tip: before approving the data sheet, compare its section 2 with the label. If the category, the H statements or the pictogram do not match, one of the two documents is wrong, and any inspection or customer audit will spot it first.
If you are preparing an aerosol under your own brand and need the documentation to arrive ready with the product, the aerosol contract manufacturing page explains each stage, from brief to shipment.
