Client Background
A boutique skincare brand based in Lisbon, selling natural cosmetic formulations into independent retailers across Portugal, Spain, and France. Their range had grown to 8 SKUs and they had just signed a distribution agreement with a multi-country European partner.
The Problem
Three days before their distributor's onboarding deadline, the brand's logistics partner flagged that the Safety Data Sheets supplied with their products were not CLP-compliant and would be rejected at the warehouse intake check.
Missing the deadline meant losing the contract — and roughly 40% of their projected annual revenue.
What We Found
- SDS authored in an older 13-section format, not the EU 16-section structure required by REACH Annex II.
- Section 2 missing several required H-statements for fragrance allergens above 0.1%.
- Section 3 disclosed substances inconsistently across the range — some INCI names, some trade names.
- Section 15 contained generic boilerplate with no reference to current EU regulation versions.
- No SVHC candidate-list check on file for any of the 8 products.
Our Process
- 1
Day 1 — Intake & triage
Received full quantitative formulas for all 8 products under NDA. Mapped each ingredient against ECHA's substance database and flagged the 3 SKUs with the highest compliance risk.
- 2
Day 2 — Classification & SVHC check
Re-classified every mixture under CLP for physical, health, and environmental hazards. Ran each substance through Annex XIV, Annex XVII, and the latest SVHC candidate list. No SVHCs above threshold — documented and dated.
- 3
Day 3 — SDS authoring
Authored all 8 SDS in the EU 16-section format, in English and Portuguese. Aligned Section 2 hazard statements with Section 15 regulatory references and Section 3 composition.
- 4
Day 4 — Label review & handover
Reviewed the printed CLP labels against the new SDS. Caught one undersized pictogram on a 50 ml jar. Delivered final document pack with version log to the brand and their distributor.
The Outcome
The distributor cleared all 8 products at warehouse intake on the first attempt. The brand kept the contract and has since used the same documentation pack for a follow-on audit by a French retailer — passed without changes.
8 / 8
Products cleared
4
Days to delivery
2
Audits passed since
"We thought we were going to lose the contract. Chemply turned a panic into a documentation pack we still use today."
— Founder, Lisbon skincare brand