Having a bit of a debate with colleagues - we buy a product from a UK supplier, which is made in the US. We have only been supplied an SDS produced under an OSHA law, nothing about Reach, etc. Is this legally compliant? Doesn't it have to be produced under Reach?

If our supplier is buying direct from the manufacturer, have they now become an importer, rather than a distributor, and do they have new requirements post-Brexit?

Thank you in advance.

Under REACH actors further down the supply chain are obliged to verify and add to the information provided by the manufacturer.

Your UK supplier has an obligation as "market supplier" to provide a REACH/CLP compliant Safety Data Sheet as a US OSHA HazCom 2012 document will just not cut it (HazCom takes no legal consideration of the Environment as this falls uder the EPA, follow a different adaptation of the UN GHS Purple Book for classification, and use ACGIH / NIOSH for work place control levels).

https://www.hse.gov.uk/chemical-classification/labelling-packaging/safety-data-sheets.htm

https://echa.europa.eu/documents/10162/23036412/sds_en.pdf/01c29e23-2cbe-49c0-aca7-72f22e101e20

page 13 of 137 gives the reference to actors in the supply chain item 2.2