Safety Data Sheets (SDS) are an essential tool for communicating the hazards of chemical substances and mixtures and providing professional users with the information they need to handle, store, transport and use chemicals safely.

In the Eurasian Economic Union (EAEU), comprising Russia, Kazakhstan, Belarus, Armenia and Kyrgyzstan, requirements for communicating chemical hazards are primarily established through a common regulatory framework.

The main instrument is the Eurasian Economic Union Technical Regulation TR EAEU 041/2017 on the safety of chemical products, adopted by Decision No. 19 of the Council of the Eurasian Economic Commission. The regulation establishes the framework for mandatory requirements applicable to chemical products placed on the market within the Union, covering aspects such as hazard classification, labelling and safety information.

TR EAEU 041/2017 was developed taking into account the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). However, the GHS is implemented within the EAEU through the Union’s own regulatory framework and should not be assumed to be implemented in the same way as in to the European Union or other jurisdictions.

For companies that manufacture, import or market chemical products in EAEU countries, this means that an SDS prepared in accordance with REACH and CLP, for example, should not automatically be considered compliant with the EAEU framework. The specific requirements of the EAEU and, where applicable, the national requirements of its Member States must be assessed.

In addition, developments in the common register of chemical substances and mixtures and the introduction of procedures relating to the notification of new substances make it necessary to keep the regulatory information used to prepare SDS up to date. Decision No. 61 of the Council of the Eurasian Economic Commission, adopted on 1 August 2025, establishes new rules for forming and maintaining the EAEU register of chemical substances and mixtures and for notifying new substances.

Summary

Key takeaway

Companies marketing chemical products in Russia, Kazakhstan, Belarus, Armenia or Kyrgyzstan must take into account the common framework established by TR EAEU 041/2017 on the safety of chemical products, as well as its implementation status and applicable national requirements. Compliance is not simply a matter of translating a European SDS or adapting an SDS that complies with REACH and CLP: classification, labelling, the safety passport, product data and, where applicable, requirements relating to the EAEU register of chemical substances and mixtures must all be assessed.

Which countries are members of the Eurasian Economic Union?

The Eurasian Economic Union (EAEU) is a supranational economic organisation currently comprising five Member States:

• Armenia
• Belarus
• Kazakhstan
• Kyrgyzstan
• Russia

All five countries participate in the Union’s common technical regulatory framework. Therefore, when a company prepares documentation to market chemical products within the EAEU, it must distinguish between the Union’s common requirements and any obligations that may still depend on the legislation of each Member State.

This distinction is particularly important for Safety Data Sheets. A company may use a single regulatory database to manage common product information, but it must check which additional territorial or administrative requirements apply to each market.

Which regulations govern Safety Data Sheets in the EAEU?

The main regulatory instrument is the Eurasian Economic Union Technical Regulation TR EAEU 041/2017, “On Safety of Chemical Products”.

The regulation was adopted through Decision No. 19 of the Council of the Eurasian Economic Commission of 3 March 2017. Its purpose is to establish common requirements to ensure the safety of chemical products placed on the market within the Union.

TR EAEU 041/2017 sets out requirements relating to various stages of chemical product management, including:

• product identification
• hazard classification
• communication of hazard information
• labelling
• safety information
• registration of chemical substances and mixtures
• assessment of certain risks
• documentation required to demonstrate compliance

Within this system, the chemical product safety passport serves as the principal safety information document for chemical products and performs a role comparable to that of an SDS in other regulatory systems.

However, the two concepts should not automatically be treated as identical. An SDS that complies with REACH does not automatically become a safety passport that complies with TR EAEU 041/2017.

TR EAEU 041/2017 on the safety of chemical products

The TR EAEU 041/2017 regulation is the central reference for companies marketing substances and mixtures subject to it.

The text establishes requirements for chemical products placed on the market within the Union and is supplemented by lists of standards and procedures adopted by the Eurasian Economic Commission.

The regulation also provides mechanisms for determining the information to be submitted about chemical products and their hazards.

For example, information used in the register may include:

• identification of the substance or mixture
• composition
• hazard classification
• labelling information
• safe handling conditions
• transport information
• safety passport data
• information on manufacturers and importers

The rules governing the register, approved through Decision No. 61 of the Council of the Eurasian Economic Commission of 1 August 2025, specifically detail the procedures for establishing and maintaining the EAEU register of chemical substances and mixtures and for notifying new substances.

How does the GHS relate to EAEU regulations?

The EAEU hazard communication system was developed taking into account the principles of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

This results in the use of concepts that are also found in other international markets, such as:

• hazard classes
• hazard categories
• signal words
• pictograms
• hazard statements
• precautionary statements

However, the EAEU has its own legal and technical framework.

Therefore, a classification carried out under another jurisdiction’s implementation of the GHS should not be assumed to be automatically valid in the EAEU.

Classification must be carried out in accordance with TR EAEU 041/2017 and the standards applicable within the Union.

The applicable EAEU framework should therefore be assessed together with the relevant standards and implementing measures developed with GHS principles in mind.

GHS does not mean identical requirements in every market

This difference is important for international manufacturers.

A company may use the same source of scientific data to classify a product in different jurisdictions, but the final regulatory classification, labelling and SDS must be checked against each legislative framework.

For example, a classification under the European Union’s CLP Regulation should not be copied directly into an SDS intended for the EAEU without first verifying the applicable criteria and standards.

This principle should also be applied to other markets where the GHS forms the basis of hazard communication.

When is an SDS mandatory in the EAEU?

The requirement to prepare a chemical product safety passport depends on the applicable regulatory framework, the scope of TR EAEU 041/2017 and its implementation, as well as the characteristics of the product concerned.

The regulation establishes information and documentation requirements for chemical products within its scope. The safety passport forms part of the information used to communicate the product’s hazards and conditions for safe use.

Therefore, before preparing an SDS for the EAEU, it is necessary to determine:

1. whether the product falls within the scope of the regulation
2. whether it is a substance or a mixture
3. which hazard classification applies to it
4. what information must be included in the safety passport
5. whether registration or notification obligations apply
6. what additional requirements may apply depending on the product and the Member State

Not all chemical products are necessarily subject to exactly the same obligations. The regulatory framework itself provides for specific scopes and exclusions, so the assessment must be carried out on a product-by-product basis.

What requirements must an SDS meet in the EAEU?

One of the main mistakes when preparing documentation for this market is assuming that translating an existing SDS is sufficient.

The safety passport must reflect the information required by the EAEU regulatory system and remain consistent with the classification, labelling and data used for product registration.

Relevant information includes:

• product identification
• composition information
• hazard classification
• labelling information
• safety measures
• storage conditions
• fire-related information
• transport information
• manufacturer and importer details
• information about the safety passport itself

The 2025 regulations on the register of substances and mixtures confirm that the safety passport forms part of the documentation and information associated with chemical product registration.

Product information

The documentation must allow the substance or mixture to be identified unambiguously.

Depending on the type of product, relevant data may include:

• chemical name
• trade name
• CAS number, where available
• identifiers specific to the EAEU system
• composition
• manufacturer
• importer
• intended uses

Consistency between these data and those used in other regulatory documents is essential.

Hazard classification

Classification is one of the central elements of the safety passport.

It must reflect the hazards identified in accordance with the criteria applicable in the EAEU.

The information used in the register may include hazard classification and the corresponding hazard communication elements, such as the signal word, hazard symbols, hazard statements and precautionary measures.

Handling and storage conditions

The document must provide information that enables the product to be managed safely.

Among other aspects, it may include:

• personal protective equipment
• storage conditions
• conditions to avoid
• incompatible substances and materials
• safety measures
• disposal or treatment methods

These data must be consistent with the product’s actual properties and hazards.

Transport information

The documentation must also contain relevant transport information where applicable.

This may include:

• UN number
• proper shipping name
• classification for the transport of dangerous goods
• packing group, where applicable
• applicable modes of transport

The EAEU register regulations expressly include transport information and refer to the United Nations Recommendations on the Transport of Dangerous Goods.

Manufacturer and importer details

The documentation must properly identify the operators responsible for the product.

The information covered by the registration system includes data such as:

• full name of the organisation
• postal address
• telephone number
• email address
• manufacturer information
• importer information

SDS management should therefore rely on consistent and reliable information on companies and products, particularly when a company works with different importers or representatives in the Member States.

What information must the safety passport contain?

The content must be assessed alongside the requirements established by TR EAEU 041/2017 and its implementing documents.

An EAEU safety passport should not be treated simply as a translated version of a European SDS following the 16-section format.

The passport must contain the information needed to communicate hazards and conditions for safe use in accordance with the Union’s system.

Relevant categories of information include:

1. product identification
2. composition information
3. hazards identification
4. first-aid measures
5. fire-fighting measures
6. accidental release measures
7. handling and storage
8. exposure controls and personal protection
9. physical and chemical properties
10. stability and reactivity
11. toxicological information
12. ecological information
13. disposal considerations
14. transport information
15. regulatory information
16. other information

Important: this 16-section structure can be used as a general reference for the types of information commonly found in safety documentation, but TR EAEU 041/2017 should not be described as a literal adoption of the REACH SDS format.

In addition, the information in the passport must be consistent with the data used in the register of chemical substances and mixtures. The 2025 regulations expressly include information on the safety passport’s version, preparation date and the person responsible for preparing it.

How does hazard classification work in the EAEU?

Hazard classification is one of the fundamental elements for determining how information about a chemical substance or mixture must be communicated in the Eurasian Economic Union.

The TR EAEU 041/2017 establishes the common framework for classifying chemical products within its scope. The system takes into account the principles of the Globally Harmonized System (GHS), but classification must be carried out in accordance with the provisions and standards applicable in the EAEU.

This means that a company should not directly transfer a classification obtained under the European CLP Regulation, US OSHA HazCom or another country’s regulations to a Eurasian SDS.

The underlying scientific information may be the same, but the regulatory criteria and the way hazards are communicated must be checked specifically for the EAEU.

Hazard classes and categories

Classification identifies the hazards associated with the product and provides the basis for determining the communication elements that must appear on the label and in the safety passport.

Depending on the characteristics of the substance or mixture, different types of hazards may be considered, including:

• physical hazards
• human health hazards
• environmental hazards

Classification must be based on available information about the product’s properties, including physical and chemical data, toxicological and ecotoxicological information and, where applicable, available information on its components.

Labelling and hazard communication

Classification is directly linked to the information that must be communicated to the user.

Elements that may be derived from classification include:

• hazard pictograms
• signal words
• hazard statements
• precautionary statements
• supplementary information required by the applicable regulations

Consistency between classification, labelling and the safety passport is essential.

A change in a substance’s classification may affect several documents and regulatory processes simultaneously. For this reason, companies should avoid managing classification and SDS authoring as separate processes.

What is the role of the register of chemical substances and mixtures?

The register of chemical substances and mixtures is another important element of the EAEU regulatory framework.

The register allows information to be collected on chemical substances and mixtures that fall within the scope of the common regulatory system and provides a basis for managing information relating to their safety.

In 2025, the Eurasian Economic Commission adopted new rules for establishing and maintaining the EAEU register of chemical substances and mixtures and for notifying new substances.

The Decision No. 61 of the Council of the Eurasian Economic Commission of 1 August 2025 establishes the relevant rules and defines the information to be included in the registration system. Among other data, it covers information on substances, mixtures, manufacturers, importers, hazard classification and safety passports.

This has an important practical consequence for manufacturers and importers: the information used for registration must be consistent with the product’s safety documentation.

Notification of new substances

The updated framework also provides for procedures for the notification of new chemical substances.

For companies developing new products or introducing substances that may qualify as new substances under the applicable framework, it is necessary to determine which notification or registration obligations apply.

The assessment must be carried out before the product is placed on the market and must take into account the provisions in force in the EAEU.

SDS management should therefore not be considered in isolation. Information on identity, composition, classification and hazards may be used in different regulatory processes and must remain consistent across them.

Requirements in Russia, Kazakhstan, Belarus, Armenia and Kyrgyzstan

One of the issues that raises the most questions among international companies is whether they must prepare a different SDS for each of the five Member States.

The TR EAEU 041/2017 establishes common requirements for the Union’s territory, so a significant proportion of chemical product obligations are managed within a supranational framework.

However, this does not mean that a company can completely disregard national requirements.

Before placing a product on the market, it is necessary to check whether national provisions apply to aspects such as:

• competent authorities
• administrative procedures
• contact information
• language
• market surveillance
• workplace requirements
• transport
• storage
• waste management
• specific obligations for certain chemical products

For this reason, companies operating in the five Member States must distinguish between the common EAEU requirements and obligations that may remain at national level.

Russia

Russia is the largest market in the EAEU and plays a significant role in the practical implementation of the Union’s regulatory system.

Companies marketing chemical products in Russia must assess the requirements of TR EAEU 041/2017 alongside any national provisions that remain applicable.

Documentation intended for the Russian market must be reviewed particularly in relation to language, economic operators and applicable administrative procedures.

Kazakhstan

Kazakhstan is part of the EAEU’s common technical regulatory system.

Chemical products marketed in the country must be assessed under the Union’s common framework when they fall within the scope of TR EAEU 041/2017.

In addition, companies must check national obligations relating to placing products on the market, competent authorities and other aspects that are not fully harmonised.

Belarus

Belarus also applies the EAEU’s common regulatory framework to chemical products subject to TR EAEU 041/2017.

Companies must check both the common requirements and any national provisions that may remain relevant to the marketing and safe use of chemical products.

Armenia

Armenia has been an EAEU member since 2015 and participates in the common technical regulatory system.

For chemical products within the scope of TR EAEU 041/2017, companies must assess the Union’s common requirements before placing the product on the market.

They must also check national requirements applicable to safety information, competent authorities and product distribution.

Kyrgyzstan

Kyrgyzstan has been part of the EAEU since 2015 and applies the Union’s common technical regulatory framework in the relevant areas.

Companies marketing chemical products in this market must check compliance with TR EAEU 041/2017 and assess any additional national requirements that may apply.

Comparison of SDS in the EAEU and other jurisdictions

Although chemical hazard communication is increasingly based on common international principles, an SDS prepared for one market cannot automatically be used in another.

Differences between jurisdictions may affect:

• classification criteria
• labelling elements
• SDS format and content
• language
• regulatory information
• competent authorities
• registration procedures
• substance notification
• national requirements

Comparison between the EAEU and other markets

Companies marketing chemical products in different markets must adapt their SDS to the specific requirements of each jurisdiction. For example, the requirements applicable in the European Union, China, Japan, South Korea, Australia and New Zealand differ from the EAEU regulatory framework.

Can a European SDS be used in the EAEU?

An SDS prepared in accordance with REACH and CLP can provide a significant proportion of the information needed to prepare documentation for the EAEU.

However, it should not be used directly without a regulatory review.

The company must check, at a minimum:

• product identity and composition
• hazard classification
• labelling elements
• specific safety passport requirements
• regulatory information
• manufacturer and importer details
• registration-related requirements
• language requirements
• potential national obligations

This process is particularly important for companies marketing the same product simultaneously in the European Union and the EAEU.

A single product database can serve as a source for both markets, but the final documentation must be generated in accordance with the specific requirements of each jurisdiction.

Recent regulatory changes

The regulatory framework for chemical products in the Eurasian Economic Union continues to evolve. For companies that manufacture, import or distribute substances and mixtures, this means that compliance with Safety Data Sheet requirements should not be considered a static process.

Developments relating to the register, classification requirements and notification procedures may affect the information used to prepare and maintain safety passports.

New rules for the register of chemical substances and mixtures

One of the most significant regulatory changes is the adoption of Decision No. 61 of the Council of the Eurasian Economic Commission of 1 August 2025.

This decision establishes new rules for establishing and maintaining the EAEU register of chemical substances and mixtures, as well as for the notification of new chemical substances.

The new framework has practical implications for manufacturers and importers, as the registration system collects information relating to:

• identity of substances and mixtures
• composition
• hazard classification
• information on manufacturers and importers
• labelling information
• safety passports
• information on new substances

The information used in these processes must be consistent with the safety documentation accompanying the product.

Notification of new substances

Developments in the registration system also introduce specific procedures for the notification of new substances.

Companies developing or introducing substances that may be considered new must determine whether they are subject to the procedures established by EAEU regulations before placing them on the market.

This adds another aspect to regulatory compliance management: in addition to keeping SDS up to date, companies must monitor the regulatory status of the substances used in their products.

Evolution of the technical framework

The TR EAEU 041/2017 provides the central technical framework for chemical product safety, but its implementation also depends on supplementary standards, lists and procedures adopted by the Eurasian Economic Commission.

Companies should therefore not rely solely on a static copy of the technical regulation.

It is necessary to monitor updates to:

• related technical standards
• substance lists
• registration procedures
• classification requirements
• labelling requirements
• notification procedures
• documentation required to demonstrate compliance

Impact on SDS

Regulatory changes may require SDS to be revised when they affect information used in the document.

For example, a change in a substance’s classification may affect:

• the classification of a mixture
• the labelling elements
• the hazard information
• the precautionary measures
• the regulatory information
• the safety passport

For this reason, regulatory monitoring must be connected to SDS management rather than operating as an independent process.

Common mistakes when preparing an SDS for the EAEU

Meeting EAEU requirements can be particularly complex for companies that already have SDS prepared for other markets.

1. Using a European SDS directly

One of the most common mistakes is assuming that an SDS compliant with REACH and CLP can be used directly in Russia, Kazakhstan, Belarus, Armenia or Kyrgyzstan.

Although both regions use concepts derived from the GHS, their regulatory frameworks are not equivalent.

The documentation must be reviewed against TR EAEU 041/2017 and the applicable standards.

2. Simply translating the SDS

Translating an existing SDS does not guarantee compliance.

In addition to language, aspects that must be reviewed include:

• classification
• labelling
• regulatory terminology
• manufacturer and importer information
• safety passport requirements
• regulatory information
• registration and notification

3. Failing to check classification against EAEU requirements

A classification carried out under the European CLP Regulation or another international system should not automatically be transferred to the Eurasian market.

Classification must be checked against the criteria applicable in the EAEU.

4. Failing to link the SDS to the register of substances and mixtures

The information in the safety passport must be consistent with the information used in registration procedures.

Maintaining separate databases for registration and SDS may lead to discrepancies in:

• composition
• classification
• substance identity
• manufacturer information
• hazard information

5. Failing to monitor new substances

The introduction of procedures for the notification of new substances makes it particularly important to know the regulatory status of the substances used in products.

A company incorporating a new substance into a formulation should first check any registration and notification obligations that may apply.

6. Manually managing versions for the five countries

Although a common regulatory framework exists, companies may need to manage different information depending on the market, the economic operator and the applicable national requirements.

Managing these versions manually increases the risk of:

• using outdated information
• creating inconsistent documents
• missing updates
• distributing the wrong version
• losing traceability of changes

Checklist: Does your SDS meet EAEU requirements?

Before placing a substance or mixture on the market within the Eurasian Economic Union, the following aspects should be checked:

This checklist can be used for an initial review, but it does not replace a product-specific regulatory assessment.

How to keep SDS compliant in the EAEU

For companies marketing chemical products in the Eurasian Economic Union, the main challenge is usually not the preparation of a single safety passport, but the ongoing management of regulatory information across multiple products and markets.

The difficulty increases when managing hundreds or thousands of products, different formulations, multiple manufacturers and importers, and regulatory updates that may affect several documents simultaneously.

In addition, many organisations market the same products in different regions. A product may need an SDS compliant with REACH and CLP for the European Union, another version for the EAEU and additional documents for other markets.

Maintaining this information through spreadsheets and separate documents makes it difficult to ensure that all versions use the same underlying data.

Centralising regulatory information

A more effective strategy is to maintain a centralised source of regulatory and product data.

This source can be used to manage elements such as:

• composition
• substances
• classification
• physical and chemical properties
• toxicological information
• ecotoxicological information
• labelling requirements
• regulatory information
• manufacturers and importers
• language versions
• safety documentation

The different versions required for each market can be generated from this information.

Monitoring regulatory changes

Change monitoring must be linked to the affected products.

For example, if the classification of a substance used in several formulations changes, the company should be able to identify which products and documents may be affected.

This approach enables a shift from reactive document management to a more controlled process of regulatory impact assessment.

Maintaining consistency between registration and SDS

The information used for the registration of substances and mixtures and the information included in safety passports must remain aligned.

For companies with large product portfolios, this is particularly important because the same substance may appear in numerous formulations.

Centralised management reduces the risk of a change being applied to one document but not to the others.

Frequently asked questions about SDS in the Eurasian Economic Union

Conclusion

Safety Data Sheets in the Eurasian Economic Union must be managed within a specific regulatory framework covering Russia, Kazakhstan, Belarus, Armenia and Kyrgyzstan.

The TR EAEU 041/2017 is the central common technical regulation for chemical product safety in the EAEU and provides the framework for requirements relating to classification, labelling and the communication of safety information.

This framework is complemented by developments in the EAEU register of chemical substances and mixtures and new procedures relating to the notification of new substances, which increase the importance of keeping regulatory information up to date and consistent.

For international companies, one of the main challenges is coordinating EAEU documentation with SDS used in other markets. A European, US or Asian SDS can provide a starting point, but it must be reviewed against the specific requirements of the EAEU before use.

How can ExESS help?

Managing Safety Data Sheets for the Eurasian Economic Union requires multiple types of information to remain aligned: composition, classification, properties, regulatory information, manufacturers, importers and document versions.

When a company markets the same products in different markets, complexity increases because a change to a substance can affect different products and different versions of their SDS.

ExESS enables companies to centralise the information used to prepare Safety Data Sheets and generate documentation tailored to the regulatory requirements of different markets.

This enables companies to:

• centralise regulatory data on substances and products
• manage different regulatory requirements from a single source of information
• generate SDS tailored to different jurisdictions
• manage multiple languages and versions
• maintain traceability of changes
• reduce manual effort associated with document updates
• more easily identify products affected by regulatory changes

For companies marketing chemical products simultaneously in the EAEU, the European Union and other international markets, a centralised source of information makes it easier to manage different regulatory versions and reduces the risk of inconsistencies between documents.