Key takeaways
- An SDS covers hazards to workers and handlers, not cosmetic performance.
- Alcohol-based products may be classified as flammable for transport.
- Aerosols and pressurised packs have their own transport rules.
A safety data sheet, or SDS, is a hazard communication document required for substances and mixtures that are classified as hazardous. A cosmetic sold to a consumer usually does not need one; a cosmetic shipped in bulk, handled by warehouse staff or containing a flammable solvent often does.
1. What an SDS covers
An SDS has sixteen sections covering identification, hazards, composition, first aid, firefighting, handling, exposure controls, physical properties, stability, toxicology, ecology, disposal, transport and regulatory information. It describes the hazards of the material, not its cosmetic benefits.
2. When one is required
An SDS is required when the mixture meets the criteria for a hazardous classification, and when a professional user requests one. A toner with 25 percent alcohol is likely to be classified as flammable and therefore needs one. A water-based cream with no hazard classification generally does not.
3. The difference from a COA
A certificate of analysis states what the material is and how it performed against specification. An SDS states what hazards it carries. A buyer who asks for an SDS to check quality has asked for the wrong document, and a supplier who provides a COA in place of an SDS has answered the wrong question.
4. Transport classification
Transport classification is determined by the flash point, the alcohol content and the packing. A product with more than a threshold of ethanol may be class 3 flammable liquid for air and sea. The classification determines the packing group, the packaging and the documentation.
5. Air versus sea
Air transport has stricter limits on flammable liquids and on pressure. A product that ships by sea without restriction can be refused by an airline. The freight forwarder needs the correct classification before booking, not after.
6. Aerosols
An aerosol or a pressurised pack has its own transport rules, including a pressure test, a classification and specific packaging. Aerosol regulation is separate from cosmetic regulation, and a brand launching an aerosol needs to plan for both.
7. Language and version
An SDS must be in the language of the destination market and must be kept current. A version from five years ago may reference a classification that has since changed. The version number and the revision date belong in the document control system.
8. Section 2 hazards
Section 2 carries the hazard statements and the pictograms. A product classified as an eye irritant carries a specific statement and a specific pictogram, which then appear on the label for professional use. Consumer labels use different wording and the SDS wording should not simply be copied.
9. Exposure scenarios
For a professional use product, an exposure scenario may be required. A salon product used by a trained operator has a different exposure than a consumer product, which is why professional and retail versions sometimes need separate documents.
10. Cost
Authoring an SDS costs a few hundred dollars per product when the classification is straightforward and more when testing is needed. The cost sits in the testing rather than the writing. A brand with ten SKUs and one flammable base can share most of the work across the range.
11. Where it fits
Transport documents run across the hair oil range; the document comparison continues in the COA entry.
Reference: SDS authoring guidance and transport classification records, 2025
