Synchronizing HS, CAS, and SDS for seamless chemical exports to the EU

IBT editorial | May 9, 2025

Exporting chemicals to the European Union requires more than just product quality—it demands flawless documentation. With stringent REACH and CLP regulations in place, aligning HS codes, CAS numbers, and Safety Data Sheets (SDS) is now essential for compliance and market access. This report highlights why synchronization of these key identifiers is critical, especially for Indian exporters, and explores the risks, regulations, and readiness required to thrive in the EU’s tightly controlled chemical trade environment.

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Chemical exporters targeting European markets face rigorous regulatory requirements that demand meticulous attention to documentation consistency. The alignment of Harmonized System (HS) codes, Chemical Abstracts Service (CAS) numbers, and Safety Data Sheets (SDS) has become a non-negotiable aspect of trade compliance. This report examines why synchronization of these elements is crucial for successful market access, the regulatory frameworks governing these requirements, and the consequences of non-compliance, with particular focus on challenges faced by Indian exporters.

REACH and CLP: Cornerstones of EU Chemical Regulation

The Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation (EC No 1907/2006) and the Classification, Labelling and Packaging (CLP) Regulation (EC 1272/2008) form the foundation of chemical governance in the European Union. These comprehensive frameworks aim to protect human health and the environment while ensuring the free movement of substances within the EU market.

However, despite these structured frameworks, non-compliance due to documentation discrepancies remains prevalent. A global review of chemical trade records between 2004 and 2019 found that 40% of all tracked records under specific HS codes were in default under the Rotterdam Convention, amounting to 25.7 megatonnes of chemicals traded in violation of import bans. This demonstrates that even within well-regulated systems, synchronizing documentation remains a widespread and unresolved challenge.

The Documentation Triad: Why Alignment Matters

The regulatory framework demands absolute consistency between three key elements:

HS/CN Codes: Determine tariff classifications and applicable regulatory measures
Chemical Identifiers (CAS numbers, CUS codes): Establish precise substance identity
Safety Data Sheets (SDS): Communicate hazard information and safe handling procedures

When these elements are misaligned, exports face detention, rejection, and financial penalties, regardless of product quality. For Indian exporters particularly, complex customs processes, documentation errors, and approval delays significantly hinder the smooth flow of chemical exports.

Data supports these concerns: Among nearly 80,000 global trade records analyzed, more than 13,000 were flagged for mislabelling or invoicing errors, and close to 10,000 were missing entirely. These issues are disproportionately concentrated in South and Southeast Asia regions with strong chemical export footprints highlighting the compliance burden for countries like India.

Understanding Key Chemical Identifiers

Customs Classification Systems: HS Codes and Combined Nomenclature

The European Union utilizes the Combined Nomenclature (CN), an eight-digit classification system based on the international Harmonized System (HS). This system is essential for determining applicable duties and non-tariff measures for chemical imports.

TARIC, the integrated Tariff of the European Union, is a multilingual database that integrates all measures relating to EU customs tariff and commercial regulations. For chemical substances, proper classification requires detailed knowledge of chemical nomenclature and composition.

Given the scale of non-compliance uncovered globally, particularly with the misapplication of HS codes, correct classification at this stage becomes vital not only for accurate duty application but for regulatory compliance. The aforementioned 40% default rate under the Rotterdam Convention is often tied to improper or inconsistent HS code usage in documentation.

Chemical Identity Systems: CAS Numbers and CUS Codes

Chemical identity is primarily established through internationally recognized CAS Registry Numbers. Additionally, the EU has developed the European Customs Inventory of Chemical Substances (ECICS), which assigns unique Customs Union and Statistics (CUS) codes to chemicals for customs declaration and regulatory purposes.

The CUS code serves as a unique 8-digit identifier (e.g., 0011481-8 for barium sulfide) that facilitates database searches and communications with EU customs authorities. Under the Import Control System 2 (ICS2), providing a CUS code is strongly recommended as part of security and safety data for chemical products entering the EU.

ECICS currently contains close to 70,000 records and is increasingly becoming “a cornerstone for customs authorities, Customs Laboratories and economic operators trading all kinds of chemicals”. But even in the European Union despite the availability of CUS codes thousands of regulatory non-conformities continue to surface, indicating that tools alone are insufficient unless properly integrated into exporters’ documentation workflows.

Safety Data Sheet Requirements Under REACH

REACH Annex II establishes specific requirements for the compilation of Safety Data Sheets, which must contain comprehensive information about substance identity, hazards, composition, handling, and regulatory status.

Recent updates to Annex II have introduced new requirements that became mandatory on January 1, 2023. These updates require all SDSs to be reissued according to the new template, which includes additional information about nanoforms and endocrine disruptors, even when the substance doesn’t contain these elements.

The consequences of failing to meet these SDS standards are now becoming quantifiable. Within the EU, regulatory audits under the Prior Informed Consent (PIC) Regulation have uncovered thousands of SDS documentation failures beyond what is visible in international trade databases, further reinforcing the need for exporters to stay ahead of compliance updates.

Synchronization Challenges and Compliance Requirements

Critical SDS Requirements for EU Market Access

For EU compliance, Safety Data Sheets must meet several stringent requirements:

SDSs must be in the official language of the Member States where the product is marketed
SDSs must follow the REACH format with sixteen mandatory sections
Email contact information for a competent person must be provided
Registration numbers must be included when available
Both DSD and CLP classification information must be included
For substances requiring Chemical Safety Reports, exposure scenarios must be annexed to the SDS
The Unique Formulation Identifier (UFI) for each product must be included

Exporters who overlook these requirements, especially the latest 2023 amendments, risk losing access to the EU market. Many Indian exporters have lost contracts despite delivering high-quality products, solely due to lapses in SDS alignment with CAS numbers and HS codes.

CLP Classification and Labeling Requirements

Under CLP regulations, manufacturers and importers must notify the European Chemicals Agency (ECHA) of substance identity and classification and labeling information through a “C&L Notification”. This information is then included in the Classification and Labeling Inventory maintained by ECHA.

CLP also introduces new pictorial ideograms featuring red-framed diamonds with various pictograms to indicate potential physical, health, and environmental hazards, replacing the orange CHIP squares previously used. The regulation aims to better help users identify hazards and take appropriate safety measures.

The export of chemicals to European markets demands an unprecedented level of documentation precision. The synchronization of HS codes, CAS numbers, and Safety Data Sheets has evolved from a bureaucratic formality to a fundamental prerequisite for market access. Indian exporters, despite having quality products, often face challenges due to complex customs processes and documentation errors.

As regulatory requirements continue to evolve, with recent SDS updates in 2023 and ongoing implementation of systems like ICS2, the importance of documentation alignment will only increase. The cost of error is no longer theoretical—from megatons of non-compliant exports to contract losses and shipment detentions, the risks are real and escalating.

Exporters must invest in developing robust systems for maintaining consistency across all chemical identifiers and documentation to successfully navigate the complex regulatory landscape of high-value markets like the European Union. Those who master this aspect of compliance will gain a significant competitive advantage in regulated markets.

Article authored by: LiquidMind ai

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