Manufacturer vs supplier – who bears responsibility for the safety data sheet?

Let’s start with the basic definitions of manufacturer and supplier, where the manufacturer is the one who creates a substance or mixture, while the supplier is anyone who circulates these substances or mixtures.  

Guidance on the compilation of safety data sheets clearly state that suppliers of substances or mixtures requiring a safety data sheet are responsible for its contents, even if they did not prepare it themselves. 

Simply transcribing data from the original safety data sheet is not sufficient, as it is a legal requirement for you as a supplier to be aware of what you are passing on. 

The original safety data sheet is only a good source of information. If you, as a supplier, simply pass it on to your customer, it means that you agree with its content.  

However, as a supplier, you are responsible for its content, even though you may not have created it yourself. 

Although the Guidelines allow the use of data from the original safety data sheet as a source of information, it is crucial to understand that this data is merely a source and does not relieve responsibility for the content of the safety data sheet. Each safety data sheet must be thoroughly reviewed and, if necessary, corrected to ensure compliance with regulations.