Guide to SDS/MSDS Creation in 2026: Step-by-Step for Candle, Fragrance & Home Fragrance Exporters

For candle makers, fragrance oil blenders, and home fragrance exporters in India, a compliant Safety Data Sheet (SDS/MSDS) is more than paperwork—it's essential for safe handling, international shipping, customs clearance, and buyer trust. In 2026, with OSHA's Hazard Communication Standard (HCS) fully transitioning to align with GHS (and select elements of later revisions), SDS requirements emphasize clearer hazard communication, updated classifications, and precise formatting.

This guide provides a practical, step-by-step process tailored for Indian exporters of scented candles, reed diffusers, melts, and fragrance oils. It draws from official GHS guidelines, OSHA's 2024 HCS final rule (effective July 19, 2024, with key deadlines in 2026–2028), and ECHA/CLP considerations for EU-bound products.

Important 2026 Notes:

• OSHA deadlines — Manufacturers/importers must update SDSs for substances by May 19, 2026 (extended from January); for mixtures (most fragrances/candles), by July 19, 2027.
• No major format overhaul to the 16-section structure, but clarifications apply to Sections 1, 2, 3, 8, 9, 10, 11, and 14 (e.g., better trade-secret ranges, particle characteristics in Section 9 for solids/waxes).
• For candles/fragrances: Final product SDS required (not just fragrance oil SDS) due to mixture hazards; integrate with ASTM F2058 labeling and IFRA limits.

Whether you're exporting to the US, EU, or Middle East, follow these steps to create accurate, compliant SDSs.

Why SDS Matters for Candle & Fragrance Exporters in 2026

• Regulatory Compliance — Required under GHS (adopted worldwide), OSHA HCS (US), CLP (EU), and India's Chemical Safety Rules.
• Export Success — Customs often demand SDS; non-compliance causes delays/rejections (common for fragrance mixtures classified as hazardous).
• Safety & Liability — Details hazards from waxes, oils, dyes, and allergens; protects workers, consumers, and your business from claims.
• Buyer Requirement — 90%+ of US/EU candle retailers demand final-product SDS + allergen declarations.

Candle-Specific Reality: A fragrance oil SDS alone is insufficient—the finished candle (wax + fragrance + wick) is the "mixture" that needs its own SDS.

The 16-Section GHS SDS Format (Mandatory in 2026)

All SDS must follow this fixed order (no changes to structure in recent updates):

1. Identification — Product name, recommended uses, supplier details (include Indian address/phone; US importers need US contact).
2. Hazard Identification — GHS classification, pictograms, signal word ("Danger"/"Warning"), hazard/precautionary statements.
3. Composition/Information on Ingredients — Chemical identity & concentration ranges (trade secrets allowed with prescribed ranges).
4. First-Aid Measures — Symptoms & immediate care.
5. Fire-Fighting Measures — Suitable extinguishing media, hazards from combustion.
6. Accidental Release Measures — Containment, cleanup methods.
7. Handling and Storage — Safe practices, incompatible materials.
8. Exposure Controls/Personal Protection — Occupational limits, PPE.
9. Physical and Chemical Properties — Appearance, flash point, melting point (include particle characteristics for wax powders if applicable).
10. Stability and Reactivity — Conditions to avoid, hazardous decomposition.
11. Toxicological Information — Acute/chronic effects, sensitization (key for fragrances).
12. Ecological Information — (Not enforced by OSHA but required internationally).
13. Disposal Considerations — Safe methods.
14. Transport Information — UN number, proper shipping name (often "Not Regulated" for candles).
15. Regulatory Information — Applicable regs (e.g., TSCA for US).
16. Other Information — Revision date, preparer details.

Step-by-Step: How to Create an SDS in 2026

1–3 weeks (with expert help)

Step 1: Determine Regulatory Scope & Product Classification

• Identify markets (US → OSHA HCS; EU → CLP/REACH; India → GHS.
• Classify the finished product: Most scented candles/fragrances are mixtures (not pure substances).
• Use GHS criteria: Check for flammable (flash point), skin sensitization (fragrance allergens), aquatic toxicity.
• 2026 Tip: Review new/desensitized explosives, updated flammable gases/aerosols if relevant.

Step 2: Gather All Required Data

Collect:

• Full formulation (CAS numbers, %, suppliers).
• Supplier SDS for each ingredient (fragrance, wax, dye, wick).
• Physical test data: Flash point, boiling/melting point, viscosity.
• Toxicological/ecotoxicological info (RIFM/IFRA data for fragrances).
• Exposure limits (e.g., ACGIH TLV for key components).

Candle Tip: Test final product for flash point.

Step 3: Classify Hazards Accurately

• Apply GHS rules to the mixture (calculation or test data).
• Common for fragrances/candles: Skin sensitization (Category 1), eye irritation, aquatic chronic.
• 2026 Update: Use updated criteria for skin/eye damage; include non-animal methods where possible.

Step 4: Draft the 16 Sections

• Write clearly, concisely (avoid marketing language).
• Use standardized phrases from GHS Annex 1/3.
• Section 3 Tip: List ingredients ≥1% (or ≥0.1% for sensitizers); use concentration ranges for trade secrets (e.g., 10–<25%).
• Section 9 Tip: Add particle size if wax is powdered.
• Section 14 Tip: Most candles = "Not dangerous goods" for transport.

Step 5: Review, Verify & Finalize

• Cross-check against regulations
• Have qualified person (chemist/toxicologist) sign off.
• Add revision date; version control.

Step 6: Distribute & Maintain

• Provide to downstream users (buyers, transporters).
• Update within 90 days of new hazard info.

Ongoing: Review + amendment tracking required.

Final Thoughts

Creating an SDS/MSDS in 2026 requires precision, especially for scented products where fragrance allergens and wax properties drive classification. Indian exporters who get this right unlock smoother US/EU shipments and stronger buyer confidence.

At Japag Regulatory Solutions, we specialize in authoring compliant SDS/MSDS for candles, fragrances, and home products—tailored for global manufacturers.

Need help navigating SDS/MSDS creation for your line? Our team specializes in simplifying global compliance. Visit our website or schedule a quick consultation to understand how we can help—accurately and efficiently.

Sources: OSHA HCS (2024 final rule), UN GHS Rev. 7, ECHA CLP guidance. Always verify latest regs. This is informational; consult experts for your products.