Hi, Anyone have any experience of ink sales into the EU? We sell solvent and eco solvent inks into Europe and are being asked for MSDS translations to native language. I understand it to be a legal requirement possibly under the Reach regulations and also under native country laws, however the cost of translation is huge.Does anyone have any advice or knowledge relating to this please. Many thanks in advance

EC 1907/2006 (REACH) Article 31:

5. The safety data sheet shall be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide otherwise.

Thing is most authoring software providers already convert the majority of the SDS content even including other matters such as national workplace exposure limits.

Belgium, Finland, Luxembourg and Switzerland are even more fun as they have more than one official language. 

Originally Posted by: Michellethirlby

however the cost of translation is huge

What are you considering "huge"?

Originally Posted by: Roundtuit

Originally Posted by: Michellethirlby

however the cost of translation is huge

What are you considering "huge"?

for every ink we have 4-6 colours so an MSDS for each one, around 15-20 variations and prices of around £2k per set

Normally paint manufacturers will batch several colours on to one SDS (where the base formulation without colourant is the same)

Typical professional SDS services are @ £200 - £300 per document so if you are getting all EU languages for £2K that seems pretty reasonable

Alan you skipped the trigger "where the substance or mixture is placed on the market"

Market = Germany the SDS (and product labelling) should be in German

Market = France the SDS (and product labelling) should be in French

Market = Finland the SDS (and product labelling) should be in Finnish BUT Swedish is also accepted

This is common in EU legislation e.g. if we look at CE marking a Certificate of Conformity or Declaration of Performance must similarly be in the language of the member state where the product is placed on the market.

Otherwise a German supplier could ship their documentation to GB in German.

"for every ink we have 4-6 colours so an MSDS for each one, around 15-20 variations and prices of around £2k per set"

Hi Michelle - though I would use red ink!

In practice how many variations do you have in the content (other than the title, product number etc) of an MSDS would there be in ENGLISH?

Assuming that you don't put specific toxic chemicals into specific colours, then I would have thought that the primary risk to be covered in the MSDSs is the solvent whether simple solvent or eco solvent (where the econ solvent is not water).

If you are exporting inks for the restoration of medieval manuscripts then I guess you might chuck all sorts of nasties into the products - but if so the translation costs into the e.g Estonian customer's MSDS are probably tiny compared to the cost of a small batch of very bespoke ink.

Originally Posted by: Pirellipete

There are many translator websites where you paste in the english and choose your required language,

Just a note of caution - the Hazard & Precuationary statements have a defined legal text which is documented in the CLP legislation, as do the headings in a Safety Data Sheet.

In this case the "cheap" option is to sit the English & required language versions of the SDS rules side by side to identify the correct text e.g.https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R0830 gives access to the various member state languages