United States focus with international comparison. Fact-checked 2026-08-23.
Does an SDS expire? Under US federal law, no fixed calendar expiration date applies to a Safety Data Sheet. OSHA uses an event-driven rule: when the party preparing the SDS becomes newly aware of significant hazard information or new ways to protect against the hazard, that information must be added within three months.
JurisdictionMulti-jurisdictionUnited StatesUnited States focus with international comparison
Age alone does not invalidate an otherwise accurate SDS. The real questions are whether the document still matches the product, reflects current hazard and protective information, and satisfies the rules of the jurisdiction or marketplace where you are using it.
Four different questions people mean by “expired”
- Expiration: a date after which a document automatically becomes void. The US Hazard Communication Standard sets no such date.
- Review: a scheduled check even when nothing has changed. Some jurisdictions require one; US federal OSHA does not.
- Revision or update: a change triggered by new information or changed facts. This is the core US rule.
- Marketplace acceptance: whether a platform accepts the file for a listing. That is separate from legal validity.
Does an SDS expire under US law?
The controlling provision is 29 CFR 1910.1200(g)(5). It requires the chemical manufacturer, importer, or employer preparing the SDS to ensure that the information accurately reflects the scientific evidence used for the hazard classification.
If that preparer becomes newly aware of significant information about the chemical’s hazards or ways to protect against them, the new information must be added to the SDS within three months. The clock starts with new awareness of significant information—not with the document’s anniversary.
Section 16 is a revision stamp, not an expiry date
Appendix D requires Section 16 to include the date of preparation or last revision. That date records when the document was written or changed. It does not start a federal validity countdown.
A sheet from 2018 is not automatically defective because it is old. But a recently dated sheet is not automatically reliable either. Compare the product identifier, formulation, classification, protective measures, responsible-party information, and any newer exact-product version available from the supplier.
The 30-year rule is recordkeeping, not validity
Under 29 CFR 1910.1020, employers generally retain employee exposure records for 30 years. An SDS can serve as part of that record. Where the SDS itself is not retained, the standard allows a record of the chemical identity and where and when it was used.
This is a historical exposure-record duty. It does not mean an SDS “expires” after 30 years or remains current for 30 years. OSHA interpretations also recognize narrow situations involving old stock or an unavailable supplier where an older MSDS may remain the most recent document received. That is not a universal permission to use an obsolete format for new products.
What actually triggers an SDS update?
| Change | Update answer | Who acts | Timing |
|---|---|---|---|
| New hazard or toxicology data | Yes, when significant | SDS preparer | Within 3 months of new awareness |
| Formulation change affecting classification or protective measures | Yes | SDS preparer | Within 3 months of new awareness |
| Regulatory change that changes the classification | Yes | SDS preparer | Apply the governing transition rule and update duty |
| Product name or brand change | Correct required identifiers; not automatically a (g)(5) hazard trigger | SDS preparer | No universal 3-month clock unless significant hazard information is involved |
| Responsible party, address, or emergency phone change | The SDS must remain accurate | SDS preparer | No universal (g)(5) clock identified for an administrative-only change |
| Supplier is out of business or unreachable | Holding the old sheet does not create an automatic authoring duty | Employer keeps the most recent version received and accessible | No age-only deadline |
| The sheet is simply old and no facts changed | No age-only federal trigger | — | None |
The pattern is simple: a hazard-relevant change starts the federal update clock. Administrative drift may not trigger that specific three-month rule, but required information still needs to be accurate.
Your role decides what you must do
- Manufacturer or importer preparing the SDS: carries the accuracy duty and the three-month significant-new-information trigger, then transmits the updated sheet with the first shipment after the update and on request.
- Distributor: transmits the current sheet with the initial shipment and the first shipment after an update. A pure distributor does not automatically become the author.
- Employer holding a supplier’s SDS: maintains the most recent version received and keeps it readily accessible during each work shift. It does not refresh the document merely because a calendar interval passed.
- Employer preparing its own SDS: assumes the preparer duties, including the three-month trigger.
If you are unsure which role applies, work out whether you need a new SDS before paying anyone to write one.
Where the 3-year and 5-year figures come from
| Jurisdiction | Fixed review interval? | Duty holder | Update rule |
|---|---|---|---|
| United States | No federal OSHA interval | Party preparing the SDS | Significant new hazard or protective information within 3 months of new awareness |
| Canada | Supplier duty is event-driven; separate employer rules require role-specific analysis | Supplier under HPR; employers under applicable workplace law | HPR 5.12 addresses significant new data and a 90-day mechanism |
| European Union | No fixed interval in REACH Article 31(9) | Supplier | Without delay after specified new information, an authorization decision, or a restriction |
| Australia | Yes—at least every 5 years | Manufacturer or importer | Five-year review plus amendment whenever necessary |
Australia’s five-year rule is a genuine review duty, but it applies within its WHS framework. Canada’s former supplier-review rule and certain current employer requirements belong to their own Canadian contexts. Neither creates a US federal expiration date. A business selling into more than one market must check the rules for each market and role.
HCS 2024 is a transition, not an expiry cycle
OSHA updated the Hazard Communication Standard in 2024 and later extended the compliance dates. The current dates confirmed by OSHA and the final rule at 91 FR 1695 are:
- May 19, 2026: manufacturers, importers, and distributors—substances (passed).
- November 20, 2026: employers—substances.
- November 19, 2027: manufacturers, importers, and distributors—mixtures.
- May 19, 2028: employers—mixtures.
During the applicable transition, covered parties may follow the previous version of the standard, the updated version, or both. These are staged compliance dates tied to a rule change. They are not a recurring SDS expiration cycle.
Marketplace acceptance is a separate test
A marketplace can reject a document that is old, generic, incomplete, unreadable, or inconsistent with the listing even when age alone would not invalidate the SDS under OSHA. The reverse is also true: platform acceptance is not a regulator’s finding that the document complies with federal law.
TikTok Shop US currently asks for a product-specific 16-section document and identifies outdated or mismatched submissions as possible rejection problems, but the reviewed public guidance does not establish one universal maximum age. Treat any “must be under X years old” claim as unverified until the platform states it for your exact workflow. For the platform-specific path, see why TikTok Shop rejected your SDS.
What to do now
Work in this order. The first four steps are free.
- Check accuracy, not age. Confirm that the SDS describes the exact product, formulation, classification, and protective measures.
- Check the identifiers. The product identifier should cross-reference the label and the item you actually sell.
- Ask for the current exact-product version. Request it from the manufacturer, importer, or supplier. The legal transmission duties depend on your supply-chain role, so do not assume every consumer seller has the same request rights.
- Ask the responsible party to correct a real defect. Do not alter a supplier’s SDS unless you are qualified and prepared to take responsibility for preparing the revised document.
- If you are the preparer and hazard-relevant facts changed, revise the sheet. Add significant new hazard or protection information within three months of becoming aware of it.
- Use paid authoring only when justified. If no defensible exact-product SDS exists and the duty is genuinely yours, compare correction and authoring options.
Before resubmitting: Review your SDS line by line → to check identity, dates, required sections, file quality, and listing consistency.
Frequently asked questions
Does an SDS expire?
Not under US federal OSHA rules. The Hazard Communication Standard sets no calendar expiration date and no fixed federal review cycle. Age alone is not the test; accuracy and current hazard information are.
How often must an SDS be updated in the United States?
There is no fixed interval. The party preparing the SDS must add significant new information about hazards or ways to protect against them within three months of becoming newly aware of it.
Is the Section 16 date an expiration date?
No. Section 16 carries the date of preparation or last revision. It records when the document was written or changed; it does not start a countdown.
Do I have to keep old SDSs for 30 years?
The 30-year figure comes from employee exposure recordkeeping under 29 CFR 1910.1020. An SDS may serve as part of the record, but retention is different from current validity.
Why did a marketplace reject my SDS if it has not expired?
Platforms apply their own criteria for product match, format, completeness, language, and consistency. A rejection is a listing decision, not a legal ruling on the SDS.
Does the Australian five-year or Canadian three-year rule apply to my US listing?
No. Australia has a live five-year review duty for manufacturers and importers. Canada’s former supplier-review rule and certain current employer requirements belong to their own Canadian contexts. None creates a US federal expiration date.
Primary sources
Last fact-checked: August 23, 2026.
- eCFR—29 CFR 1910.1200 Hazard Communication
- OSHA—Appendix D, Safety Data Sheets
- OSHA—29 CFR 1910.1020 Exposure Records
- OSHA—HCS 2024 Compliance-Date Extension
- Federal Register—Hazard Communication Standard, 91 FR 1695
- Health Canada—WHMIS Supplier Guidance
- Canada Labour Program—Employer SDS Guidance
- EUR-Lex—Consolidated REACH Regulation, Article 31
- Safe Work Australia—Preparing Safety Data Sheets
- TikTok Shop US—Guide to Obtaining an SDS
This guide is informational and not legal advice. Regulations, transition dates, State Plan requirements, and marketplace policies can change. Verify the current text and the exact request in your account before relying on it. XrdaGrid does not guarantee legal compliance or a listing outcome.