What is an MSDS? Considerations Material Safety Data Sheet
MSDS (Material Safety Data Sheet), also known as a chemical safety data sheet, is a mandatory technical document for hazardous chemicals in manufacturing, trading, importing, and transporting goods. However, many businesses still confuse an MSDS with a product label, or assume it is only required for air freight and overlook it in sea freight and domestic distribution.
In practice, a missing or non-compliant MSDS can result in a shipment being refused by the carrier, detained at customs, or the business being penalized under the Law on Chemicals. The article below provides a comprehensive explanation from 3W Logistics of what an MSDS is, the responsibilities of each party involved, the mandatory content of a chemical safety data sheet, current legal regulations, and the types of goods that require an MSDS in import and export operations.
1. What Is an MSDS?
What is an MSDS? MSDS stands for Material Safety Data Sheet. It is a technical document providing comprehensive information about the physical and chemical properties, toxicity, hazard level, emergency response procedures, and protective measures for a specific chemical or chemical mixture.
In international trade and logistics, an MSDS is also known as an SDS (Safety Data Sheet) under the United Nations’ GHS (Globally Harmonized System of Classification and Labelling of Chemicals) – an internationally standardized version of the traditional MSDS. In Vietnam, the terms “phiếu an toàn hóa chất” (chemical safety data sheet) and “MSDS” are used interchangeably in practice.
Download the MSDS template here
How is an MSDS different from a product label? A product label affixed to the packaging provides only a summary (product name, key ingredients, basic hazard warnings). An MSDS is a far more comprehensive document – typically 10–20 pages long – providing sufficient information for all parties to handle a chemical safely in any situation, including emergencies.
2. The Role of an MSDS
An MSDS is not only a legal requirement – it is a practical safety tool for every party in the chemical supply chain. Below are the roles an MSDS plays for each group of stakeholders:
| Party | Role and Significance of the MSDS |
|---|---|
| Manufacturer / Exporter | Has a legal obligation to prepare and provide an MSDS before a chemical is placed into circulation or exported; the MSDS is the basis for classifying dangerous goods (DG), applying correct labeling, and determining appropriate packaging and transport conditions |
| Importer / Distributor | Must have an MSDS to complete chemical import procedures, assess risks before taking delivery, and comply with storage and distribution requirements; a missing MSDS can result in goods being held at the border or barred from market circulation |
| Freight Forwarder / Carrier | Needs the MSDS to determine the IMDG code (sea freight), IATA code (air freight), or ADR code (road transport) for dangerous goods; this establishes the applicable handling, storage, and container requirements (e.g. temperature-controlled or ventilated containers) as well as transport restrictions; the MSDS is the basis for dangerous goods declarations submitted to the carrier or airline |
| Workers / Employees with Direct Exposure | The MSDS is the most practical guide available for personal protective equipment (PPE) requirements, exposure precautions, and first-aid procedures in cases of chemical poisoning or burns; the law requires organizations to ensure that all workers exposed to hazardous chemicals are provided with the MSDS and trained on its contents |
| Customs Authorities and Regulatory Agencies | Use the MSDS to verify cargo classification, determine HS codes, check import conditions, and assess compliance with chemical regulations; the MSDS is a mandatory document in the import dossier for hazardous chemicals |
| Emergency Responders / Incident Response Teams | In the event of a spill, fire, explosion, or chemical poisoning, the MSDS is the first document responders consult to identify the substance, determine appropriate firefighting methods, establish safe isolation zones, and administer initial treatment |
Practical insight from 3W Logistics: In international shipping, many shippers only think about the MSDS when the carrier or airline requests it as an additional document – by which point the cargo cutoff is usually imminent. Preparing the MSDS early – as soon as the purchase contract is signed – prevents schedule delays and avoids unnecessary container storage charges.
3. Required Content of a Chemical Safety Data Sheet (MSDS)
In accordance with Annex 9 of Circular 32/2017/TT-BCT and the international GHS standard, a complete MSDS must contain 16 sections in the following standardized order:
| Section | Section Title | Required Content |
|---|---|---|
| 1 | Identification of the Chemical and Manufacturer Information | Chemical name, trade name, other names; CAS registry number; intended use; manufacturer/supplier information (name, address, 24/7 emergency phone number) |
| 2 | Hazard Identification | GHS hazard classification; warning pictograms; signal word (Danger/Warning); hazard statements (H-statements) and precautionary statements (P-statements) |
| 3 | Composition / Information on Ingredients | Name and concentration (%) of each chemical component; CAS numbers; hazardous components requiring disclosure above threshold concentrations |
| 4 | First-Aid Measures | First-aid instructions for each exposure route: inhalation, skin contact, eye contact, ingestion; symptoms to monitor; when to seek medical attention |
| 5 | Firefighting Measures | Suitable and unsuitable extinguishing media; hazardous combustion products; protective equipment for firefighters; special explosion and fire hazards |
| 6 | Accidental Release Measures | Personal protective measures when handling a spill; methods to prevent spreading; cleanup procedures; waste collection and disposal requirements |
| 7 | Handling and Storage Requirements | Safe storage conditions (temperature, humidity, light, ventilation); chemicals that must not be stored together; packaging conditions for transport; transport restrictions by mode |
| 8 | Exposure Controls / Personal Protection | Occupational exposure limits (OEL/TLV); engineering controls (ventilation, exhaust systems, etc.); personal protective equipment (PPE): gloves, goggles, respirators, protective clothing |
| 9 | Physical and Chemical Properties | Physical state, color, odor; boiling point, melting point, flash point; solubility, density, vapor pressure; pH; other relevant properties |
| 10 | Stability and Reactivity | Chemical stability; conditions to avoid (high temperature, light, moisture, etc.); incompatible materials; hazardous decomposition products |
| 11 | Toxicological Information | Acute toxicity (LD50, LC50); effects on skin, eyes, and respiratory tract; carcinogenicity, mutagenicity, reproductive toxicity; chronic effects from long-term exposure |
| 12 | Ecological Information | Aquatic toxicity; bioaccumulation potential; biodegradability; effects on soil and groundwater |
| 13 | Disposal Considerations | Methods for treating and disposing of the chemical and its packaging; legal requirements for hazardous waste; prohibited disposal methods (discharge to drains, uncontrolled landfill, etc.) |
| 14 | Transport Information | UN Number; Proper Shipping Name; Hazard Class; Packing Group; transport restrictions by mode (sea / air / road) |
| 15 | Regulatory Information | Applicable regulations in the country of manufacture and the country of destination; international chemical control registration numbers; use restrictions or prohibitions (if any) |
| 16 | Other Information | MSDS preparation date; date of last revision; version number; list of reference documents; additional notes and recommendations from the manufacturer |
Note: Among the 16 sections above, Section 14 (Transport Information) is the most critical for freight forwarders and carriers. The UN Number, Hazard Class, and Packing Group in this section are the basis for declaring dangerous goods to the shipping line (under the IMDG Code) or the airline (under IATA DGR). Missing or incorrect information in this section can result in the shipment being refused.
4. How Are Chemical Safety Data Sheets (MSDS) Regulated?
In Vietnam, chemical safety data sheets are governed by the following legal framework:
Primary legal basis: Clauses 1 and 2 of Article 24 of Decree 113/2017/NĐ-CP (as amended by Decree 82/2022/NĐ-CP) stipulate that hazardous chemicals and mixtures containing one or more hazardous substances must have a chemical safety data sheet prepared when the concentration of the hazardous substance meets or exceeds the prescribed threshold. Organizations and individuals manufacturing or trading in hazardous chemicals must provide the chemical safety data sheet to all parties involved in chemical activities.
Concentration thresholds triggering the MSDS obligation under Article 24 of Decree 113/2017/NĐ-CP (as amended by Decree 82/2022/NĐ-CP):
| No. | Hazard Classification | Minimum Concentration |
|---|---|---|
| 1 | Acute toxicity | ≥ 1.0% |
| 2 | Skin corrosion / irritation | ≥ 1.0% |
| 3 | Serious eye damage / eye irritation | ≥ 1.0% |
| 4 | Skin / respiratory sensitization | ≥ 1.0% |
| 5 | Germ cell mutagenicity (Category 1) | ≥ 0.1% |
| 6 | Germ cell mutagenicity (Category 2) | ≥ 1.0% |
| 7 | Carcinogenicity | ≥ 0.1% |
| 8 | Reproductive toxicity | ≥ 0.1% |
| 9 | Specific target organ toxicity — single exposure | ≥ 1.0% |
| 10 | Specific target organ toxicity — repeated exposure | ≥ 1.0% |
| 11 | Aspiration hazard (Category 1) | ≥ 1.0% |
| 12 | Aspiration hazard (Category 2) | ≥ 1.0% |
| 13 | Hazardous to the aquatic environment | ≥ 1.0% |
Language requirements and MSDS preparation responsibilities: Under Clause 3, Article 24 of Decree 113/2017/NĐ-CP and Article 7 of Circular 32/2017/TT-BCT (as amended by Circular 17/2022/TT-BCT):
- Chemical safety data sheets must be prepared in Vietnamese; imported chemicals may be accompanied by a foreign-language MSDS, but a Vietnamese-language version is mandatory before the chemical is put into use or placed into market circulation.
- Organizations and individuals manufacturing or importing hazardous chemicals must prepare an MSDS before the chemical is put into use or placed into circulation and are legally responsible for the accuracy of its contents.
- Organizations and individuals must keep the MSDS on-site for all hazardous chemicals in their possession and ensure that all persons involved with those hazardous chemicals are provided with the MSDS.
- The Ministry of Industry and Trade is the lead agency for guidance on MSDS preparation pursuant to Annex 9 of Circular 32/2017/TT-BCT.
Note on MSDS updates: An MSDS must be updated whenever the composition or properties of the chemical change, when new toxicological information becomes available, or when relevant regulations are amended. The preparation date and date of last revision must be clearly stated in Section 16. An outdated MSDS or one that does not accurately reflect the actual composition of the imported shipment may prompt customs authorities to require a replacement to be submitted.
5. Which Goods Require an MSDS?
Not all goods require an MSDS. Below is a classification of cargo types that do and do not require an MSDS in import/export and transport operations:
| Cargo Type | MSDS Required? | Specific Examples |
|---|---|---|
| Industrial chemicals | ✔ Mandatory | Acids (HCl, H₂SO₄, HNO₃), alkalis (NaOH, KOH), solvents (methanol, acetone, toluene), oxidizing agents, reducing agents, industrial catalysts |
| Paints, varnishes, and surface coatings | ✔ Mandatory | Solvent-based paints, epoxy coatings, varnishes, anti-corrosion coatings, industrial cleaning agents containing hazardous ingredients |
| Lithium batteries and accumulators | ✔ Mandatory | Lithium-ion batteries, lithium metal batteries, lithium accumulators shipped loose or installed in electronic devices; among the most tightly regulated cargo in air freight (IATA Section II/IA/IB) |
| Fuels, oils, and gases | ✔ Mandatory | Gasoline, diesel, lubricating oil, LPG, compressed gas in cylinders; industrial lubricants containing hazardous chemical components |
| Fertilizers and agricultural chemicals | ✔ Mandatory | Pesticides (insecticides, herbicides, fungicides), chemical fertilizers (particularly nitrogen and potassium fertilizers), soil treatment chemicals |
| Cosmetics and cleaning products | ⚠ Depends on composition | Perfumes (high alcohol content), hair bleaching products, hair dyes, nail polish (flammable solvents), concentrated cleaning agents with high corrosivity – must be assessed based on actual composition |
| Functional foods and pharmaceuticals | ⚠ Depends on composition | Pharmaceuticals containing controlled or hazardous active ingredients; laboratory and clinical trial chemicals; bulk antibiotic substances |
| Standard electronic equipment and machinery | ✗ Not required | Computers, mobile phones (excluding shipments of loose lithium batteries), mechanical machinery containing no hazardous chemicals, textiles, handicrafts |
| Standard food products and agricultural commodities | ✗ Not required | Rice, coffee, seafood, standard packaged food, fresh fruit, vegetables — containing no hazardous chemical components above the prescribed thresholds |
Note for air freight: Airlines apply IATA DGR (Dangerous Goods Regulations) very strictly. Many goods that appear harmless – nail polish, perfume, power banks, insect repellent sprays – are classified as dangerous goods when transported by air and must be accompanied by an MSDS together with a Dangerous Goods Declaration (DGD). Violations can result in heavy fines and transport bans.
6. Who Issues an MSDS and Where Is It Obtained?
This is a question many importing businesses get confused about: an MSDS is not issued by a government authority. The law places the responsibility for preparing an MSDS on the organization or individual that manufactures or imports the chemical – no government body “issues” or “approves” an MSDS as a permit.
| Situation | Who Is Responsible for Preparing the MSDS |
|---|---|
| Domestically manufactured chemicals | The manufacturer is responsible for preparing the MSDS in Vietnamese before placing the product on the market; the MSDS accompanies the goods and must be provided to all customers throughout the distribution chain |
| Imported chemicals | The foreign exporter provides an MSDS in accordance with international standards (GHS) with the shipment; the Vietnamese importer is responsible for translating it into Vietnamese (if a Vietnamese version is not already provided) and is legally accountable for the accuracy of that translation before placing the goods into domestic circulation |
| Chemicals in mixtures / contract-manufactured products | The blending or contract manufacturing entity is responsible for preparing an MSDS for the finished product; if the mixture contains hazardous components above the threshold, a new MSDS must be prepared for the mixture – the individual component MSDSs cannot serve as a substitute |
Where can importing businesses obtain an MSDS?
- Request from the foreign supplier: This is the most common and correct approach. When signing a chemical purchase contract, include a clause requiring the supplier to provide an MSDS (in English and/or Vietnamese) for each shipment and to update it whenever the composition changes.
- Prepare it in-house (for importers who also blend or repackage): Businesses that import raw materials and repackage them under their own brand must prepare their own MSDS for the finished product in accordance with the guidance in Annex 9 of Circular 32/2017/TT-BCT.
- Engage a specialist consultant: Chemical safety consulting firms, independent testing laboratories, and some technical/chemistry universities can assist with preparing and translating MSDSs to the required standard.
- Search international databases: Many major chemical manufacturers (BASF, Dow, 3M, etc.) publish their MSDSs publicly on their websites; MSDSs can also be found through databases such as ChemSRC, SigmaAldrich, and GESTIS. However, it is essential to verify that the MSDS belongs to the correct manufacturer and that the version is still current.
“In practice, the most frequently overlooked requirement is the Vietnamese-language translation of the MSDS. Many importers have an English MSDS from their supplier but have not yet translated it into Vietnamese and find themselves scrambling when customs or an inspection team requests it. 3W Logistics recommends that clients prepare bilingual versions at the time of receiving each shipment.” – Ms. Apple, CCO, 3W Logistics
FAQ – Frequently Asked Questions About MSDS
Question 1: Are MSDS and SDS the same thing?
MSDS (Material Safety Data Sheet) and SDS (Safety Data Sheet) are essentially the same document. SDS is the standardized name under the United Nations’ GHS (Globally Harmonized System), which mandates a uniform 16-section structure and has been adopted by many countries since the 2010s. MSDS is the older term, less standardized, with the number of sections varying between countries. In international trade today, SDS/GHS is the preferred term, but “MSDS” remains widely used in practice.
Question 2: What are the penalties for importing chemicals without an MSDS?
Under Decree 71/2019/NĐ-CP on administrative penalties in the chemicals sector, an organization that does not have a chemical safety data sheet for a hazardous chemical may be fined between VND 10 million and VND 30 million. In addition, the shipment may be held at the border crossing and barred from market circulation until the complete documentation is provided.
Question 3: Does an MSDS have an expiry date?
Vietnamese law does not prescribe a fixed validity period for an MSDS. However, businesses are obligated to update the MSDS whenever there is any change in the chemical’s composition, hazardous properties, or toxicological information, or when relevant regulations are amended. Under international practice (GHS), an MSDS should be reviewed periodically – at least every 3 years — or immediately when new information becomes available.
Question 4: What specific information does an MSDS need to include for air freight?
When transporting dangerous goods by air, in addition to the MSDS, the forwarder must also prepare a Dangerous Goods Declaration (DGD) in accordance with IATA DGR standards. The DGD must specify the UN Number, Proper Shipping Name, Hazard Class, Packing Group, quantity, and weight in accordance with the applicable regulations – all of which are drawn from Section 14 of the MSDS. Dangerous goods transported by air are subject to stricter quantity and packaging restrictions than sea freight.
Question 5: Do Vietnamese exports of chemicals need to comply with the importing country’s MSDS requirements?
Yes. When exporting chemicals to overseas markets, Vietnamese businesses must provide an MSDS that complies with the regulations of the importing country. For example: exports to the EU must have an SDS compliant with REACH Regulation (EC) No. 1907/2006; exports to the United States must comply with OSHA HazCom 2012; exports to Japan must comply with JIS Z 7253. Each market has its own specific requirements for language, hazard classification, and disclosure thresholds – specialist advice should be sought before the first shipment is sent.
Question 6: Do lithium batteries in phones or laptops require an MSDS when exported?
Yes. Lithium batteries are classified as Class 9 dangerous goods under both IMDG and IATA. Whether shipped as batteries contained in equipment or as loose batteries, commercial shipments in significant quantities must be accompanied by an MSDS and declared in compliance with the applicable IATA Section IA, IB, or II requirements depending on the battery type and capacity. Lithium batteries are currently among the most closely scrutinized cargo types by airlines worldwide.
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Email: info@3w-logistics.com
Website: www.3w-logistics.com
Ms. Apple is the CCO (Chief Commercial Officer) at 3W Logistics, with over 10 years of experience in sales and business operations management.
At 3W Logistics, Ms. Apple is responsible for commercial strategy, corporate customer development, managing a team of more than 50 sales professionals, and improving business performance in the logistics sector.
With practical experience in sales management and market development, Ms. Apple shares professional insights on business logistics solutions, international transportation, freight forwarding, customer management, trade lane development, and growth strategies in the logistics industry.
