Nonsensia Ltd · version 1.0 · effective 14 July 2026
Editorial document under legal review. Clauses §9 (liability) and §10 (governing law) are provisional pending a lawyer’s approval. Not legal advice.
We provide services to businesses only (B2B) — not to consumers.
This document states what we do and, just as plainly, what we do not. The limits matter as much as the scope — so we spell them out loud.
§1. Definitions
| Term | Meaning |
|---|---|
| Provider | Nonsensia Ltd, Company No. 15165427, 124–128 City Road, London EC1V 2NX, United Kingdom; contact: [email protected] |
| Client | a business (services offered B2B only — not to consumers) |
| dhscientific.com | a demonstration store for the MOL-GOD platform (molgod.org) running in sandbox mode — it shows how the services work and does not sell anything |
| SDS | Safety Data Sheet under Art. 31 and Annex II of Regulation (EC) 1907/2006 (REACH), in the format of Regulation (EU) 2020/878 |
| Destination market | the specific EU/EEA Member State into which the Client places the product |
| MOL-GOD canon | the Provider’s decision base: (CAS, commercial form) → registry fields with a source link and validity date |
| Layer A | fields transcribed from public registries (CLP Annex VI · H/P/EUH · pictograms · SCL · ADR · waste code · national OELs) — no professional judgment |
| Layer B | fields requiring professional judgment (e.g. first aid, PPE, spill procedures) — require a competent person under REACH Annex II |
§2. Scope — four services
The Provider offers four services. Everything else visible in the store (substance encyclopaedia, ADR data, regulatory alerts, dashboard, programmatic interfaces) is a feature of the MOL-GOD platform, not a separate service sold on its own.
A. SDS Compliance Audit
We check the Safety Data Sheet you already have against Regulation (EU) 2020/878 and a defined list of registry criteria (§3). Deliverable: an audit report — every finding with its legal basis and a link to the source registry. We do not fix the sheet — we point out the errors.
B. CLP Labels & Product Stickers
Print-ready labelling per Articles 17–33 of Regulation (EC) 1272/2008 (CLP), in the destination-market language: product identifiers · EU supplier details · nominal quantity · GHS pictograms · signal word · H statements · P statements · supplemental EUH information · UFI code where applicable — respecting the minimum label and pictogram dimensions of CLP Annex I.
C. Chemical Store Build & Deployment
From the Client’s product list (minimum input: two columns — CAS and name; everything else optional) we prepare an evaluation draft of the store within 72 hours. The draft runs in sandbox mode (no orders, no payments), on a password-protected address, marked noindex. Full deployment and maintenance — per the offer and an individual quote. The 72-hour draft is available to Clients of a paid audit. Use of the Client’s logo and materials in the draft is governed by §5a.
D. SDS — Structurally Complete Draft (*)
We prepare a draft of the 16-section Safety Data Sheet in Polish, in which the Layer-A fields (public-registry transcription) are filled in and carry a provenance trail.
(*) This is a draft, not a document ready to be placed on the market. The draft is structurally complete, but 5 of its 16 sections require a competent person under REACH Annex II (Layer-B fields — professional judgment) (sections 4, 5, 6, 7 and 8.2). Formal competent-person review and sign-off is not part of this service — it is a separate service or the Client’s own consultant; our provenance trail makes their work substantially faster. We do not present this draft as a „ready” or „signed” SDS.
We prepare SDSs in Polish only. We do not promise Safety Data Sheets in other official languages. (CLP labels — service B — are prepared in the destination-market language.)
UFI-code generation and mixture SDSs — under construction. As of today this is not a catalogue service; it is delivered only under a separate quote. Within the audit (service A) we do, however, check for the presence of a UFI where applicable.
§3. Audit criteria (service A) — published, so you can check us
The audit verifies the presence and formal correctness of the elements below. Each maps to a deficiency category ECHA inspectors recorded in campaign REF-11 (December 2024: over 2,500 inspected sheets, 35% non-compliant — https://echa.europa.eu/-/compliance-of-safety-data-sheets-still-room-for-improvement).
| # | Check | Basis | Layer |
|---|---|---|---|
| 1 | 16-section format per Reg. (EU) 2020/878 (mandatory since 1 Jan 2023) | 2020/878 | A |
| 2 | Official language of the destination Member State | REACH Art. 31(5) | A |
| 3 | Section 2.1 — classification against the harmonised CLP Annex VI entry (Index No.); detects both illegal softening and inflation from summing C&L notifications (phantom hazards raise your customer’s transport and storage costs) | CLP Annex VI | A |
| 4 | Section 2.2 — completeness of H, P and EUH statements (EUH codes do not exist in GB 30000 or US HazCom — no Chinese or American template will generate them) | CLP Annexes II–IV | A |
| 5 | Section 2.2 — pictograms and signal word consistent with the classification | CLP Art. 17 | A |
| 6 | Section 8.1 — destination-country OELs with their legal basis stated | national law + IOELV directives | A |
| 7 | Section 8.2 — PPE specific, not generic: EN standard, material, glove thickness, permeation breakthrough time | REACH Annex II | A* |
| 8 | Section 14 — UN number, proper shipping name, class, packing group | ADR / IMDG / IATA | A |
| 9 | Section 15 — REACH Annex XVII / XIV / SVHC Candidate List status, destination-country national law (a Section 15 citing Chinese regulations is a non-EU marker), and presence of a UFI for hazardous mixtures | REACH Art. 31 · CLP Annex VIII | A |
* Why check 7 matters.
Noticing that Section 8.2 omits glove thickness, the EN standard and breakthrough time is registry transcription (Layer A) — no chemist required. Supplying the correct values is Layer B and requires a competent person. The audit does the first; the §2.D draft supplies the Layer-A fields, and a competent person completes Layer B.
§4. Limits — stated plainly
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We do not sell „REACH compliance.” Compliance is a legal state depending on registration, tonnage and your role in the supply chain. Anyone selling it as a software feature is misleading you.
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We are not a law firm and not an Only Representative (REACH Art. 8). We do not file ECHA registrations.
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An SDS is a legal document. Responsibility for its content rests with the entity placing the substance or mixture on the EU market (importer, downstream user or OR) — not with us. Section 1.3 (supplier details) and final approval are yours.
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REACH Annex II requires a competent person. Layer-A fields are delivered finished; the SDS draft (§2.D) is not issued as a signed document or one ready for the market — 5 of its 16 sections are completed by a competent person (a separate service or the Client’s own consultant).
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An audit is not a guarantee of passing inspection or clearing customs. It removes the documentation defects inspectors most commonly find. We do not guarantee that a shipment will not be challenged — nobody can honestly promise that.
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You are responsible for the accuracy of the input data — CAS, composition, concentrations, commercial form, tonnage.
HCl (gas)andHCl (37% solution)are two different documents; if you supply the wrong form, the output will be wrong. -
dhscientific.com is a demonstration store in sandbox mode. It does not sell; it demonstrates how the platform works. It must not be treated as a commercial offer of chemical products.
§5. Confidentiality
- Your documents and data (especially mixture composition needed for UFI/PCN) are treated as your trade secret. The Provider does not disclose them to third parties and does not use them outside performing the contract.
- On request we sign a separate NDA before composition is disclosed.
§5a. Client’s trademark and materials
1. Licence. For the purpose of preparing the store draft for evaluation (§2.C), the Client grants the Provider a free of charge, non-exclusive, revocable and time-limited licence to use its trademark, logo, trade name and graphic materials.
2. Scope — exclusive and closed. The licence covers solely the preparation of, and the Client’s access to, the evaluation draft. It does not cover any other use — in particular marketing, portfolio, reference or publication in any form.
3. Safeguards — the Provider undertakes that the draft:
a) is served only from a password-protected address on the Provider’s subdomain;
b) carries noindex, nofollow and is excluded in robots.txt (Disallow: /);
c) is not published and not disclosed to third parties;
d) runs in sandbox mode — it accepts no orders and no payments;
e) expires automatically after 30 days.
4. Deletion. On expiry, or on the Client’s first request, the Provider deletes the Client’s logo and graphic materials from its systems, excluding backups subject to standard rotation.
5. Client’s representation and warranty. The Client represents and warrants that it holds the rights to the trademark, logo, trade name and graphic materials provided, to the extent necessary to grant the licence in clause 1, and that their use under this section does not infringe the rights of any third party.
6. Responsibility for rights. Responsibility for the rights to the trademark, logo, trade name and graphic materials supplied to the Provider rests with the Client.
7. Revocation. The Client may revoke the licence at any time. The Provider removes the logo without undue delay; the draft remains available with neutral branding.
8. No consent. Withholding the licence does not prevent the preparation of the draft. The draft is built with neutral branding.
9. No transfer. Nothing in this agreement transfers any rights in the Client’s trademark to the Provider.
§6. MOL-GOD canon — licence, not ownership
- Layer-A transcription performed for you (public registries for a given
CAS + commercial formpair) enters the MOL-GOD canon. - You receive a perpetual, non-exclusive licence to use the resulting documents and data in your business; you do not acquire exclusive rights to the canon.
- The final documents (audit reports, labels, SDS drafts) are yours to use without restriction within your own supply chain.
- The Client may use the documents within its own supply chain without restriction; reselling the documents as a standalone product requires the Provider’s separate written consent.
§7. Quote, pricing, timing
- Quotes are individual and depend on: number of items (CAS × form), number of destination markets, hazard class of the portfolio. Current terms and price ranges — in the offer.
- All prices are a starting point — negotiable.
- Starter audit: 5 Safety Data Sheets per company — €0. Uniform, with no per-sheet variants.
- Written quote within 48 hours of receiving your product list. Evaluation store draft (§2.C) — within 72 hours of complete input data.
- The contract takes effect on your written acceptance of the quote.
- Timelines run from delivery of complete input data.
§8. Updates
NDS lists are amended. The SVHC Candidate List grows twice a year. CLP Annex VI receives further ATPs. Monitoring regulatory changes for items in the canon is a feature of the MOL-GOD platform, available under a separate quote. Without active change-alert monitoring, the Provider does not monitor regulatory changes for documents already issued.
§9. Liability
The Provider’s liability is capped at the fee received for the given service. Liability for lost profits, downtime, the Client’s contractual penalties towards its counterparties, and demurrage costs is excluded. The cap does not apply to wilful misconduct or gross negligence.
§10. Governing law and jurisdiction
The governing law is the law of England & Wales; the courts of England & Wales have jurisdiction (consistent with the Provider’s seat). The parties may agree arbitration in the contract (e.g. LCIA or HKIAC).
§11. Substantive complaints
Report an error in a delivered document to [email protected]. Every report is verified against the source registry. A Layer-A error confirmed against the registry is corrected free of charge, and the correction is published in the canon.