An audit service by DH Scientific — powered by the MOL-GOD platform. An audit is not a guarantee that your shipment clears customs — nobody can honestly promise that. It is a documented list of the defects EU inspectors most commonly find, with the law next to each one.
You already have a Safety Data Sheet. It has 16 sections. It has pictograms. It looks professional.
The question that costs you money is not „do I have an SDS?” — it’s „will this one survive an EU compliance officer, or a customs hold?”
In ECHA’s REF-11 enforcement campaign (published 3 December 2024), inspectors across 28 EU/EEA countries checked over 2,500 Safety Data Sheets, and roughly a third were recorded as non-compliant — and those were overwhelmingly EU-based suppliers, working inside the EU system. (ECHA REF-11)
A document written to China GHS (GB 30000) or US OSHA HazCom cannot be fixed by translating it — it is structurally missing entire categories of legally required content.
And the stakes are not only regulatory: a document failure at the border can cost you the European buyer’s trust and the account, even when the product itself is fine.
Proof, not promises. Every finding we return cites its legal basis and links to the source registry, so you can verify us in sixty seconds. Where no verified source exists, we say so.
What we actually sell: the diagnosis
Send us the SDS you already have. We send back a report.
Not an opinion. A table: nine registry checks, each mapped to a deficiency category ECHA inspectors actually record, each finding carrying three states — PASS / FAIL / NOT VERIFIABLE — with its legal basis and a source link on every line.
No false precision. You never get „your card is 62% compliant.” You get: „3 of 9 checks failed. 2 could not be verified. 4 passed.”
The audit identifies the errors. It does not rewrite your card. Noticing that Section 8.2 omits glove thickness is registry transcription — no chemist needed. Supplying the correct value requires a competent person. That is a different, separately quoted matter (see the honest note below).
The nine checks — in full
❶ Format — 16 sections per Reg. (EU) 2020/878
We check: the sheet uses the current 16-section layout mandatory since 1 January 2023. Older Annex II layouts (e.g. a missing subsection 9.2) fail on sight.
Legal basis: Commission Regulation (EU) 2020/878 → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0878
Verification: formal — presence of the required structure.
❷ Language — official language of the destination country
We check: the sheet is in the official language of the country you are shipping to. Poland needs Polish. Germany needs German. English alone works only in Ireland and Malta. This failure is visible in one second — but only if you tell us the destination country. If you don’t, this check returns NOT VERIFIABLE, not a guess.
Legal basis: REACH Art. 31(5) → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02006R1907-20250101
Verification: formal.
❸ Classification — against the harmonised CLP Annex VI entry
We check: Section 2.1 classification against the binding Annex VI entry (by Index number). Two ways to fail:
– classify more leniently than the binding Annex VI entry — illegal;
– copy the union of all public self-classification notifications — phantom hazards that inflate your customer’s transport and storage costs and make the buyer lose trust in you when the card is audited.
Where a CAS has form-dependent entries (e.g. HCl: gas 017-002-00-2 vs solution 017-002-01-X), we check that the sheet used the entry matching the commercial form you actually sell — the most frequent silent error in non-EU cards.
Legal basis: CLP Annex VI, Table 3 → https://echa.europa.eu/information-on-chemicals/annex-vi-to-clp
Verification: formal — correct binding entry cited.
❹ EUH statements — supplemental EU hazard information
We check: Section 2.2 for EU-specific supplemental statements. Codes such as EUH014, EUH031, EUH066, EUH208 do not exist in GB 30000 or US HazCom — no Chinese or American template will ever produce them. Their absence is a signature of a non-EU document.
Legal basis: Regulation (EC) No 1272/2008 (CLP), Annexes II–IV → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008R1272
Verification: formal — presence/absence against expected codes.
❺ Pictograms & signal word — consistent with the classification
We check: Section 2.2 GHS pictograms and the signal word (Danger / Warning) are consistent with the declared classification.
Legal basis: CLP Art. 17 → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008R1272
Verification: formal — internal consistency.
❻ Section 8.1 — occupational exposure limits, with legal basis stated
We check: Section 8.1 states a national occupational exposure limit for your destination market and cites the legal act it comes from. REF-11 records „OEL without legal basis” among its most frequent findings.
– Every destination market — presence and legal basis. We confirm a national OEL and its cited act are present for the country you export to; where we do not hold that country’s numeric register we verify presence and legal basis only, and we say so on the check.
– Where we hold the national register — value-verified. For some markets we also check the number. Verifiable example: acetone — the EU indicative limit is 1210 mg/m³, while a national binding limit can be 600 mg/m³, twice as strict. A card showing only the EU value gives that country’s employer legally wrong data for workplace risk assessment.
Legal basis: the national OEL act of the destination market — Poland’s NDS/NDSCh regulation (Dz.U. 2018 poz. 1286) is one example → https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20180001286
Verification: presence and legal basis for every market; value where we hold the national register.
❼ Section 8.2 — PPE that is specific, not generic
We check: four elements. „Wear suitable protective gloves” is a finding, not a description.
| Element | Present? |
|---|---|
| EN standard (e.g. EN 374-1 type A/B/C) | ✔ / ✘ |
| Glove material | ✔ / ✘ |
| Glove thickness (mm) | ✔ / ✘ |
| Permeation breakthrough time | ✔ / ✘ |
Noticing that thickness is missing is a registry check — no chemist needed. Supplying the correct value needs a competent person.
Legal basis: REACH Annex II → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02006R1907-20250101
Verification: formal — presence of the four elements.
❽ Section 14 — transport (ADR / IMDG / IATA)
We check: UN number, proper shipping name, class and packing group. Misdeclared dangerous goods is the fastest way to lose an EU freight forwarder permanently.
Legal basis: ADR 2025 (UNECE) · Directive 2008/68/EC → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008L0068
Verification: formal against the declared substance/form.
❾ Section 15 — REACH restrictions, authorisation, SVHC, national law, UFI
We check: Annex XVII (restrictions), Annex XIV (authorisation), SVHC Candidate List, the destination country’s national law, and — for mixtures classified as hazardous — the UFI. A Section 15 citing Chinese regulations is an instant marker that this is not an EU document.
Legal basis: REACH Art. 31 · CLP Annex VIII (Reg. (EU) 2017/542) → https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32017R0542
Verification: formal — presence and EU legal grounding.
Five cards, not one — because one card hides the real problem
The free audit covers five documents per company. One card shows an incident. Five cards show whether the defect is in your template. A defect that appears in every card we check is not an accident — it is built into the system you generate your documentation from. Fixing the template fixes everything at once; fixing them one card at a time costs far more.
We write „probably every card in your catalogue has this defect” — probably, not certainly, because we checked five, not all. We do not guess.
Why the audit is free — and why it’s fast
The audit is registry transcription, not chemistry. Every one of the nine checks asks „is the required element present and correctly sourced?” — a question a registry and a checklist answer, not a chemist. That is why we can run it quickly and give it away: the value we spend is a lookup, not lab judgement.
File format — we accept text only
✅ PDF with a text layer · DOC / DOCX · ODT · RTF · TXT
❌ JPG · PNG · BMP · scanned PDF (a scanned PDF is still a PDF — and contains not one letter of machine-readable text)5-second test: open the card →
Ctrl+F→ typeCAS→ nothing found? It’s a scan. Ask your documentation department for the source file.We do not run OCR. OCR can misread a digit in a CAS number or a concentration — and a wrong digit in a safety document can hurt the person handling the chemical. We do not guess.
Audit pricing
| Tier | Scope |
|---|---|
| Free audit | 5 SDS per company |
| START | up to 10 SDS |
| CATALOG | up to 25 SDS |
| FULL | up to 50 SDS |
| Over 50 SDS | full catalogue |
Pricing for every service lives on one page — see the offer page. Every price there is a starting point and negotiable.
Turnaround: the free audit (5 SDS) — report within 5 working days; paid tiers (START / CATALOG / FULL) — within 7 working days, counted from complete, text-based files.
If you need the document itself — an honest note
We do not sell a rewrite, a „cure”, or a finished, signed SDS. A Safety Data Sheet is a legal document, and REACH Annex II requires a competent person to compile it.
What we can produce is a structurally complete draft* built on EU registry data — a starting point, in the destination-country language. Of its sixteen sections, five require competent-person judgement (sections 4, 5, 6, 7 and 8.2), not registry transcription. So the draft is something you (or your own regulatory consultant) finish and sign off — it is never a ready-to-ship, signed SDS, and we do not present it as one. Priced individually.
* Draft only. Not a compliance deliverable, not promoted as one.
CLP labels & product stickers — print-ready (a separate line)
The SDS travels with the paperwork. The label travels on the drum, and inspectors see it first. We produce print-ready artwork compliant with Articles 17–33 of Regulation (EC) 1272/2008, in the destination country’s language, containing:
- Supplier details — name, address and telephone of a supplier established in the EU (Art. 17(1)(a)). These are your (the client’s) EU supplier details — the EU-established entity on the CLP label is yours to provide, not ours.
- Nominal quantity for packages made available to the general public
- Product identifiers — name, CAS/EC, Index number where the substance appears in Annex VI
- GHS pictograms — each covering at least 1/15 of the label surface and never smaller than 1 cm²
- Signal word — Danger or Warning
- Hazard (H) and precautionary (P) statements, plus supplemental (EUH) information
- UFI code — for hazardous mixtures, on the label and in SDS subsection 1.1
| Package capacity | Minimum label dimensions (verify vs CLP Annex I before print) |
|---|---|
| ≤ 3 litres | 52 × 74 mm |
| > 3 and ≤ 50 litres | 74 × 105 mm |
| > 50 and ≤ 500 litres | 105 × 148 mm |
| > 500 litres | 148 × 210 mm |
We also flag, per substance, whether the packaging additionally needs a tactile warning of danger (raised triangle) or child-resistant fastenings.
Label pricing: pricing for every service lives on one page — see the offer page. Every price there is a starting point and negotiable.
What we are not — stated plainly
- We do not sell „REACH compliance” as a checkbox. Compliance is a legal state depending on registration, tonnage and your role in the supply chain. Be suspicious of anyone who sells it as a software feature.
- We are not a law firm and not an Only Representative (REACH Art. 8). We can explain the landscape (full legal roadmap →) and tell you what to ask a REACH consultant.
- An audit is not a guarantee your shipment clears customs. It removes the defects inspectors most commonly find. Nobody can honestly promise more.
Auditable, not merely „compliant.”
Start
Send us your SDS — up to five per company. Tell us which country you export to. The report is free.
Start with the one you are least sure about.
- Where: Contact → · [email protected]
- What you get back: the nine-point audit report —
PASS/FAIL/NOT VERIFIABLEon each check, with legal basis and source link on every finding - If you then want to act: a written quote within 48 hours for labels — per product, per destination market. Need a store? CAS + product name is enough to start; a working draft in 72 hours (audit clients).
DH Scientific is operated by Nonsensia Ltd (Company No. 15165427, London — verifiable in the UK Companies House register). Terms: Terms of Service. Science first. Commerce as consequence.