Why are there differences in allergens declared on a Safety Data Sheet vs Allergen Declaration?

These two documents have a different definition of what you might call an “allergen” which relates to the different regulations involved.

The allergens which appear in the Allergen Declaration relate to a specific list of allergens from the Cosmetic regulation, and these allergens need to appear on the label of the cosmetic pack if above specified levels. All allergens present in the item are typically shown on the declaration. In Formpak you can see which allergens will be declared by looking at the property ‘AGNINGDETAILS’ in the Cosmetic and Detergent property group.

The allergens which appear in a Safety Data Sheet are based on the Safety Data Sheet regulation, which also relates to the GHS/CLP regulation. In this case the list contains ingredients classified as allergens according to GHS/CLP and present above a specific level. The levels for declaration vary based on the category of the allergen. Under CLP there two rules which lead to declaring allergens:

1. Which allergens are present above a level which causes the whole product to be classified as an allergen. These allergens will appear in the property ‘CLPSDSINGDETAILS’ in the CLP Hazards property group.
2. Lower level allergens which must be identified on the label to alert people who may already be allergic. This is a supplemental requirement EUH208. In Formpak you can see these allergens in property ‘CLPSENSINGDETAILS’ in the CLP Hazards property group.