Who Is Obligated to Have an SDS, and When Does That Obligation Arise?
One day a corporate customer or a marketplace sends you a single-line email: "Could you please send us the safety data sheet for your product?" At that moment, your workshop stops being a kitchen and you become a person placing a product on the market. This article is here so you are prepared before that email arrives.
An SDS (Safety Data Sheet — known in Turkey as GBF, Güvenlik Bilgi Formu) is a technical document that communicates a substance's or mixture's hazards, and its safe handling, storage, transport, first-aid, and disposal information in a standardised sequence. It protects the user — but it also protects you, because being able to say "I provided the information" is the first item in any defensible file.
The regulatory framework in Turkey is clear: after 31/12/2023, SDS documents must be prepared exclusively in accordance with the KKDİK Regulation. Safety data sheets for substances and mixtures placed on the Turkish market must be prepared in conformity with Annex 2 of the KKDİK Regulation and in Turkish. The structure of the document is not optional either: the relevant regulation specifies 16 main sections and 48 sub-sections. An SDS is therefore not an "information note" — it is a document whose format is mandated by law.
In the world of fragrance oils, three distinct product families fall under three separate regulatory regimes. A room fragrance or diffuser liquid is a chemical mixture. A perfume applied to skin is a cosmetic. A surface cleaner falls under detergent legislation. The fact that they are produced on the same bench does not mean they share the same paperwork.
| Product type | Primary regulatory framework | Is an SDS required in practice? | Other documents typically requested |
|---|---|---|---|
| Room fragrance, diffuser liquid, car air freshener | KKDİK + SEA (classification and labelling) | Yes — mandatory as a rule where a hazard classification exists; virtually unavoidable for alcohol- or solvent-based products | Label text, hazard statements (H/P) |
| Skin perfume, cologne, body spray | Cosmetics legislation (TİTCK) | A classical SDS is not expected for the finished product; SDS documents for raw materials must be in the file | Product Information File + Safety Assessment Report |
| Surface cleaner, laundry fragrance, detergent | Detergent legislation + SEA | Yes | Technical file (including biodegradability data) |
| Fragrance oil, aroma chemical, solvent (B2B sale) | KKDİK + SEA | Yes — communicating information down the supply chain is the primary obligation | IFRA compliance statement, certificate of analysis |
| Solid articles/products such as candles and soap | Varies by product type | Case-by-case; raw material SDS documents are retained regardless | Allergen declaration, label |
There is a frequently overlooked point on the detergent side: manufacturers must keep a technical file on their premises — comprising the product's safety data sheet, label, and test data relating to the biodegradability of surfactants — ready to be submitted to the Ministry on request. This file is not sent to the authority proactively; it must simply be available for inspection. The misconception that "it was never asked for, so it can't be necessary" can prove very costly on the day of an inspection.
On the cosmetics side, what companies often assume to be an exemption is, more often than not, nothing of the sort. Any exemption from cosmetics regulations is limited to formulations that fall within the scope of the cosmetic product definition as set out in legislation; the most widespread error companies make is assuming their products are entirely exempt and thereby neglecting their SDS and labelling obligations. Furthermore, a registration exemption does not remove classification, labelling, or SDS obligations: even a hazardous substance that is exempt from registration must still be labelled and communicated to the supply chain via a safety data sheet.
What Data Do You Need to Provide to the Preparer?
The quality of an SDS depends on the quality of the data you supply even more than on the preparer's expertise. Incomplete data means conservative (overstated) classification. Overstated classification means unnecessary transport restrictions, alarming labels, and lost corporate customers.
- The complete and precise formula — by weight (% w/w)
The name of every component, its CAS/EC number where available, and its weight percentage. By weight, not by volume. "Approximately 10% or so" is not acceptable; the total must add up to 100.00.
- A current SDS for every raw material
Fragrance oil, ethanol, IPM, MPG, DPM, solubilizer, antioxidant — all of them. Request updated versions from your supplier for any that are out of date. The preparer calculates the mixture's properties from component-level data.
- The fragrance oil's allergen and IFRA documents
The fragrance oil's IFRA compliance statement and allergen list. Limits apply not to the total fragrance oil percentage but to the individual substances within the oil and the product category (leave-on / rinse-off).
- Measured physical data
Appearance, colour, scent, density, pH (for aqueous systems), and flash point. Flash point can be estimated by calculation, but if the transport classification is critical, an accredited laboratory measurement is required.
- Packaging and usage scenario
Is it a spray or a reed diffuser? 100 ml or 5 L? Will it be used by consumers or professionals? The exposure scenario directly determines first-aid and precautionary statements.
- Company and emergency contact details
Company name, address, email, and a genuinely reachable emergency telephone number. The number listed in Section 1 must actually be answered.
- Variant list
If you have 30 scents on the same base, say so upfront. If the preparer works on a "base + fragrance family" logic, both time and cost drop significantly.
Now for a practical pitfall that nobody mentions: grams and millilitres are not the same thing. You build your formula in grams, but you fill your bottle in millilitres. The specific gravities of fragrance oils and solvents vary across a wide range — citrus-forward oils can drop to around 0.84, while heavy resins and some synthetics can exceed 1.10. If you ignore density, the "100 g" you put into a 100 ml bottle will either overflow or fall short.
| Component type | Typical density range (g/ml, ~20°C) | How many ml does 100 g give? | Note |
|---|---|---|---|
| Ethanol (high-grade) | ~0.79 – 0.81 | ~124 – 127 ml | The component that occupies the most volume by far |
| Citrus-forward fragrance oil/essential oil | ~0.84 – 0.88 | ~114 – 119 ml | Light; volume errors are largest here |
| IPM (isopropyl myristate) | ~0.85 | ~118 ml | A carrier/emollient, not a fixative |
| MPG (monopropylene glycol) | ~1.03 – 1.04 | ~96 – 97 ml | Leaves a tacky feel on skin at high concentrations |
| Heavy resin/balsam, some synthetics | 1.05 – 1.15+ | ~87 – 95 ml | Small volume, high mass; can be misleading on the scale |
One more note worth making: MPG and IPM are frequently described in the market as "fixatives." They are not. They are carrier solvents and emollients that indirectly contribute to longevity by moderating volatility to a degree, and that is all. What we properly call fixatives are macrocyclic musks, glucose ether-type molecules, and heavy balsams/resins. Use the correct terminology both in your SDS and in your marketing copy — the wrong term creates the wrong expectation.
The Process, Timeline, and Lifespan of the Document
An SDS is not a one-off task. It is a living document that is created, maintained, and updated. When your formula changes, so does the SDS.
- Scope determination
Which legislation does your product fall under? Cosmetics, chemical mixture, or detergent? A process that starts with the wrong scope is wasted effort from the outset.
- Selecting a preparer and signing an NDA
Check the validity date of the preparer's certificate. Sign the non-disclosure agreement. Share your variant count upfront.
- Delivering the data package
The seven items from Section 03. If the package is complete, the turnaround is shorter; if it is incomplete, the preparer will classify to the worst-case scenario.
- Classification and calculation
The mixture's hazard class, H/P statements, and pictograms are determined in accordance with SEA rules. A laboratory test may be requested if necessary.
- Reviewing the draft SDS
You should verify the company information in Section 1, the emergency telephone number, the product name, and the packaging details. This is where the most common errors appear.
- Aligning the label with the SDS
Section 2 of the SDS and the packaging label must be consistent. Present in the document but absent from the label is the first discrepancy caught during an inspection.
- Archiving and distribution
Send the document to corporate customers and distributors, and archive a dated copy. Keep a record of who received which version.
- Monitoring and updating
Initiate a revision whenever the formula, supplier, packaging, or legislation changes. The revision number and date must always be clearly visible.
| Trigger event | Does the SDS need updating? | Why |
|---|---|---|
| You changed your fragrance oil supplier | Yes | The allergen profile and component data change |
| You increased the fragrance oil rate from 8% to 15% | Yes | Classification thresholds may be crossed |
| You switched the solvent from DPM to ethanol | Yes | Flash point and transport regime change |
| Only the label design changed | No | Hazard data remains the same |
| Packaging increased from 100 ml to 5 L | Usually yes | Usage scenario and transport conditions change |
| Legislation/classification was updated | Yes | The document must conform to the current rule |
There is a second clock running in the background: the KKDİK registration timeline. This timeline has been phased — the final registration deadlines are staggered according to tonnage and substance hazard: 31.12.2026, 31.12.2028, and 31.12.2030. The deadline for pre-registration was set as 30 September 2026; 31 December 2026 applies to substances manufactured or imported at 1,000 tonnes per year or more and to certain high-hazard categories; 31 December 2028 to 100 tonnes per year or more; and 31 December 2030 to 1 tonne per year or more.
A small workshop will rarely reach these tonnage thresholds — but your supplier will. A raw material that has fallen out of registration may one day appear as a gap in your supply chain. It should therefore become routine to ask your supplier about the registration status of your key raw materials. And remember: a deferral does not remove the registration obligation; it merely shifts the timeline.
Preparing for Customer Requests and Frequently Asked Questions
Corporate customers usually ask for an SDS urgently. They ask the day before an order. That is why the document must be ready before the order arrives. Everything else is just your signature.
There is also the export door. If you are selling to the EU, the rules of the game change: companies exporting from Turkey to EU countries need to share the mixture's formula information so that the EU importer can fulfil PCN and UFI code requirements. For domestic Turkish sales, the picture is different: the EU basis is CLP Annex VIII, whereas in Turkey the framework runs through SEA and SDS legislation; no national UFI system has been introduced, and poison centre notification is the obligation of the manufacturer and importer. Implementation in this area can change rapidly — always verify the current position before signing a contract.
I sell room fragrances and I operate at a small scale — is an SDS still mandatory?
Do I need to have an SDS prepared for a skin perfume as well?
Can I change the logo on my supplier's SDS and use it for my own product?
Can I prepare the SDS myself — wouldn't a template be sufficient?
Can the SDS be in English — is my overseas supplier's form sufficient?
I produce 25 different scents on the same base — do I need a separate SDS for each?
Are an SDS and a cosmetic safety assessment report the same thing?
If my product is exempt from KKDİK registration, am I also exempt from the SDS?
Do I have to put a UFI code on the label in Turkey?
My customer needs it tomorrow — can an SDS be turned around in one day?
If a fragrance oil is labelled "food grade", does that mean my product is suitable for food use?
I made a product with natural ingredients — will the SDS process be easier?
Do I need to carry out a skin test before placing my product on the market?
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