Desiccant MSDS Handbook — Safety Documentation for US, EU & Japan Export Markets
The complete guide to MSDS/SDS for export desiccants (silica gel, clay, CaCl₂): all 16 GHS sections, full CAS/EC/UN numbers, US OSHA 1910.1200 + EU REACH + Japan JIS Z 7253 requirements, CEMACO's per-shipment document workflow, Declaration of Conformity, and the 5 most common customs MSDS errors.

TL;DR — Full Article Summary in 3 Minutes
An MSDS (Material Safety Data Sheet) — now officially called an SDS (Safety Data Sheet) under the GHS system — is a mandatory regulatory document when exporting desiccants (silica gel, clay bentonite, or CaCl₂ powder) to the US, EU, and Japan. Even though all three desiccant types are classified as safe (non-flammable, non-corrosive, non-acutely toxic), B2B buyers and import customs authorities still require a properly formatted 16-section GHS SDS.
This guide covers: 16 GHS SDS sections applied to desiccants, CAS/EC/UN numbers for all three types, market-specific regulations (US OSHA 1910.1200, EU REACH EC 1907/2006, Japan JIS Z 7253), CEMACO's SDS delivery workflow, when you need a DoC/LoNO/CFS, and the 5 most common MSDS errors at customs.
All CEMACO MSDS templates are available at MSDS Silica Gel 2025 and MSDS Clay 2025 — free download after leaving your email.
1. What Is an MSDS? From MSDS to GHS SDS — The International Regulatory Context
History: ANSI Z400.1 → GHS → 16-Section SDS
Before 2012, countries used different MSDS formats — the US followed ANSI Z400.1 (16 sections), the EU used Directive 2001/58/EC (16 sections in a different order), and Japan used JIS Z 7250. Shipments crossing multiple borders required multiple MSDS versions, creating cost and confusion.
In 2003, the United Nations published the GHS (Globally Harmonized System of Classification and Labelling of Chemicals) — a unified global framework. GHS is not law itself but a framework for countries to adopt:
- US: OSHA updated HCS 2012 (29 CFR 1910.1200), mandating 16-section SDS from June 1, 2016.
- EU: REACH EC 1907/2006 Article 31 + Annex II (revised by EU 2020/878) — 16-section SDS mandatory from January 1, 2023.
- Japan: JIS Z 7252:2019 (classification) + JIS Z 7253:2019 (labeling + SDS) — equivalent to GHS Revision 7.
Terminology note: Since 2012, "SDS" is the official GHS term. "MSDS" is the legacy term still widely used in trade. In this article, both terms are used interchangeably to reflect actual industry practice.
Why Do Desiccants Need an MSDS Despite Being Safe?
Silica gel, clay, and CaCl₂ powder are not hazardous chemicals under OSHA or GHS definitions. However, an SDS is required or expected by:
- OSHA 29 CFR 1910.1200: Any chemical substance in a workplace — even "minimally hazardous" ones — requires an SDS when the manufacturer chooses to provide one, and in practice all US importers require it for customs clearance.
- EU Customs (REACH): Any substance imported into the EU above 1 tonne/year must have a compliant Annex II REACH SDS.
- B2B Buyers: The HSE (Health, Safety & Environment) departments of importers require SDS to conduct workplace risk assessments — especially when warehouse staff handle large quantities of desiccant daily.
- ISO 9001 & HACCP Audits: Both internal audits and customer audits require complete technical documentation for all input materials — including desiccant sachets used in food production lines.
See also: HACCP Certification for Desiccant Packets to understand the relationship between MSDS and HACCP documentation.
MSDS vs CoA vs TDS — How Are These Three Technical Documents Different?
Export companies frequently confuse these three documents:
- MSDS/SDS: Safety document — describes chemical composition, health hazards, emergency response (fire, spill, inhalation), GHS classification, transport UN number. Issued at the product/type level, valid 3 years.
- CoA (Certificate of Analysis): Quality analysis certificate — actual test results for each production batch. Includes: SiO₂ content, moisture absorption at RH 50%/80%, pH, purity, production date, batch number. See CoA Silica Gel Batch 2025 Q1.
- TDS (Technical Data Sheet): Performance specifications sheet — surface area, pore size, moisture adsorption isotherms, particle size, operating temperature range. No safety or regulatory information. See TDS Silica Gel 2025.
A complete export documentation set requires all three: MSDS + CoA (per batch) + TDS. The MSDS is the most critical document for customs clearance.
2. The 16 GHS SDS Sections — Detailed Explanation for Desiccants
According to GHS and OSHA HCS 2012, a valid SDS must include exactly 16 sections in the following order. Here is each section explained specifically for silica gel, clay, and CaCl₂:
| # | Section Name | Key Content for Desiccants | Important Note |
|---|---|---|---|
| 1 | Identification | Trade name, chemical name, manufacturer, 24/7 emergency phone, intended use (desiccant for packaging) | Must include emergency phone — CEMACO: +84-983-929-232 |
| 2 | Hazard(s) Identification | Silica gel: Not classified (GHS). Clay: Not classified. CaCl₂: Skin irritant H315, Eye irritant H319 — low severity | CaCl₂ needs GHS07 pictogram (exclamation mark); silica gel and clay require no pictogram |
| 3 | Composition / Information on Ingredients | CAS, EC number, % composition. Silica gel: SiO₂ ≥99% CAS 7631-86-9. Clay: Montmorillonite CAS 1302-78-9. CaCl₂: CAS 10043-52-4 | Missing CAS number is the most common customs rejection reason |
| 4 | First-Aid Measures | Inhalation: move to fresh air. Eye contact: flush with water 15 min. Ingestion: drink water, no induced vomiting — silica gel/clay harmless; CaCl₂ causes mild gastric irritation | Must specify when medical attention is needed |
| 5 | Fire-Fighting Measures | Silica gel and clay: non-flammable, do not support combustion, no toxic fumes when burned. CaCl₂: non-flammable. Use CO₂, dry powder, water for surrounding materials | Packaging material (non-woven/Tyvek) may ignite with direct flame |
| 6 | Accidental Release Measures | Vacuum with HEPA filter industrial equipment, avoid creating silica dust. CaCl₂ spill: neutralize with bicarbonate, do not drain to sewer | Silica gel fine dust <1 µm may cause lung irritation with prolonged exposure |
| 7 | Handling and Storage | Avoid dust generation, wear N95 mask when handling large quantities. Store dry <30°C, RH <60%, avoid water contact. Keep packaging sealed until use | Used silica gel should not be reused for food applications without regeneration and new CoA |
| 8 | Exposure Controls / PPE | OEL amorphous silica: 10 mg/m³ (OSHA PEL). Crystalline silica: 0.05 mg/m³ OSHA Action Level — commercial silica gel is amorphous, much lower risk. Controls: N95 respirator, ventilation, safety glasses when weighing/dispensing | Distinguish amorphous silica (gel) from crystalline silica (quartz) — very different exposure limits |
| 9 | Physical and Chemical Properties | Silica gel: white opaque/translucent beads, odorless, MP >1600°C, bulk density 0.7–0.8 g/cm³, insoluble in water, non-flammable. pH slurry: 5–7 | Include separate data for each type (silica gel/clay/CaCl₂) if the product is a blend |
| 10 | Stability and Reactivity | Silica gel and clay: stable under normal conditions, no polymerization, no decomposition. CaCl₂: reacts vigorously with concentrated alkalis, caution near NH₃ | State conditions to avoid (extreme heat, strong acids) |
| 11 | Toxicological Information | Amorphous silica gel: LD50 >22.5 g/kg (rat, oral) — not acutely toxic. Long-term dust inhalation: silicosis risk (amorphous much lower than crystalline). Clay montmorillonite: non-toxic. CaCl₂: LD50 1,000 mg/kg (rat) | Clearly distinguish amorphous vs crystalline silica to avoid unnecessary concern |
| 12 | Ecological Information | Silica gel and clay: not aquatically toxic, no bioaccumulation, not biodegradable (inorganic). CaCl₂ in water: elevated Cl⁻ may affect fish and aquatic plants at high concentrations | Declare per EU CLP and REACH — include EC50 if data is available |
| 13 | Disposal Considerations | Silica gel and clay: dispose as ordinary solid waste (non-hazardous). Saturated CaCl₂: dilute before draining. Single-use packaging: recycle per local regulations | EU WFD 2008/98/EC — EWC code 16 03 06 for non-hazardous desiccants |
| 14 | Transport Information | Amorphous silica gel: no UN number — Not Regulated (IMDG sea freight, IATA air). Clay: Not Regulated. Anhydrous CaCl₂: UN 1453, Class 5.1 (only when >99% pure anhydrous) | Distinguish pure CaCl₂ from commercial desiccant form (blend/encapsulated) — most commercial CaCl₂ desiccants are Not Regulated |
| 15 | Regulatory Information | US: TSCA Listed. EU: REACH pre-registered/registered, not on Annex XIV (SVHC). Vietnam: Circular 32/2017/TT-BCT. Not CERCLA, not RoHS, not POPs | For cobalt blue silica gel: clearly state cobalt chloride is SVHC under ECHA — disclose to customers |
| 16 | Other Information | SDS issue date, version (e.g. "Version 4.0 — 01/01/2025"), last revision date, references (OSHA 1910.1200, REACH Annex II, GHS Rev.9), abbreviation list, SDS author | Mandatory to include effective date and version number — an SDS without a date is invalid |
3. MSDS Standards by Market — US, EU, Japan
| Criterion | US (OSHA HCS 2012) | EU (REACH Annex II) | Japan (JIS Z 7253:2019) |
|---|---|---|---|
| Governing law | 29 CFR 1910.1200 | EC 1907/2006 Annex II | JIS Z 7252:2019 + JIS Z 7253:2019 |
| SDS sections | 16 (mandatory) | 16 (mandatory) | 16 (mandatory, GHS Rev.7) |
| Language requirement | English (official workplace language) | Official language of the member state receiving the goods | Japanese mandatory |
| GHS revision applied | Rev.3 (OSHA 2012) — updating to Rev.7 under HCS 2024 | Rev.7 (ATP 15 CLP) | Rev.7 (JIS 2019) |
| CAS number requirement | Mandatory | Mandatory + EC number | Mandatory + ENCS number |
| Desiccant-specific requirement | TSCA listing; FDA GRAS Letter for food-contact use | REACH registration (>1 tonne/year); EC 1935/2004 for food-contact | Food Sanitation Act compliance for food chain use |
4. CAS, EC, UN Numbers — Complete Table for 3 Desiccant Types
| Desiccant Type | Chemical Name | CAS Number | EC Number | UN Number (transport) | GHS Hazard Class |
|---|---|---|---|---|---|
| Silica Gel Type A/B (white) | Silicon dioxide, amorphous | 7631-86-9 | 231-545-4 | Not regulated (IMDG sea & IATA air) | Not classified |
| Cobalt Blue Silica Gel | SiO₂ + Cobalt(II) chloride | 7631-86-9 + 7646-79-9 | 231-545-4 + 231-589-4 | Not regulated (blend <0.1% CoCl₂) | GHS08 (CMR) for CoCl₂; SVHC under ECHA |
| Clay Desiccant (Bentonite) | Montmorillonite clay, activated | 1302-78-9 | 215-108-5 | Not regulated | Not classified |
| Calcium Chloride Desiccant | Calcium chloride, anhydrous | 10043-52-4 | 233-140-8 | UN 1453 Class 5.1 (pure anhydrous >99% only); commercial desiccant blends typically Not Regulated | GHS07 (H315, H319) for pure form; blended desiccant typically Not classified |
Reference: UN GHS Purple Book — the authoritative source for chemical classification and labeling. See also our comparison article: Comprehensive Comparison: Silica Gel vs Clay vs CaCl₂ Desiccants.
5. CEMACO's MSDS Delivery Workflow per Shipment
CEMACO maintains a standardized process to provide a complete technical document package with every order. This process is built on CEMACO's ISO 9001 quality management system, which mandates document control, version tracking, and traceability from raw material batch to finished goods. Every customer — whether ordering 100 packets or a full container — receives the same standard of documentation. The process has 6 steps:
- Step 1 — Customer request via RFQ: When filling out the quote request form, select "Request technical documentation." The technical team prepares: MSDS + TDS + sample CoA (most recent batch) + ISO 9001 + HACCP certificates — delivered within 4 business hours.
- Step 2 — QC Lab batch testing: Every production batch is tested for: moisture absorption at RH 50% and 80%, SiO₂ content (ICP-OES), pH, particle size (sieve analysis), purity. Results recorded in a CoA to ISO 17050 format. See example: CoA Silica Gel Batch 2025 Q1.
- Step 3 — Issue MSDS batch version: The product MSDS (v4.0, 2025) is fixed per product line. When composition changes significantly (e.g. new raw material source, new additive), the MSDS is updated with a new version number and effective date. Each MSDS bears the company seal and authorized signature.
- Step 4 — Pack documents with shipment: Each container or export shipment is accompanied by a hard-copy document set: MSDS + batch CoA + Technical Packing List. PDF versions are sent by email and Zalo to the customer's import-export team when the batch is picked.
- Step 5 — Customs declaration support: The CEMACO sales team assists with HS codes (3824.99 for silica gel desiccant, 2508.10 for bentonite clay, 2827.20 for CaCl₂), English commodity descriptions for Form E (ASEAN C/O) and EUR.1 (EU C/O).
- Step 6 — Version control and record retention: All MSDS versions and batch CoAs are retained for 5 years under ISO 9001 document control. Customers may request batch-specific documents within 3 years. View current certifications at ISO 9001 + HACCP certificates.
5b. MSDS vs CoA vs TDS — Detailed Comparison Table
Export procurement teams frequently encounter three distinct technical documents from desiccant suppliers: the Material Safety Data Sheet (MSDS/SDS), the Certificate of Analysis (CoA), and the Technical Data Sheet (TDS). While all three are issued by the manufacturer and reference the same product, they serve fundamentally different purposes, target different audiences, and carry different validity periods. Understanding which document to request — and which regulatory body requires it — prevents delays at customs, QC holds, and failed supplier onboarding audits. The table below provides a structured comparison across eight criteria relevant to B2B export procurement.
| Criterion | MSDS / SDS | Certificate of Analysis (CoA) | Technical Data Sheet (TDS) |
|---|---|---|---|
| Document type | Chemical safety information document (16 GHS sections) | Batch-specific analytical test report | Product performance and specification datasheet |
| Purpose | Communicate hazards, safe handling, emergency response, and transport classification to workers and customs | Confirm that a specific production batch meets agreed quality specifications | Describe product characteristics, performance curves, and application parameters for engineering and procurement decisions |
| Validity period | Static — valid until composition or regulatory status changes; reviewed every 3 years at minimum; effective date stated in Section 16 | Batch-specific — unique to each production batch; expires when that batch is consumed; typically issued alongside delivery note | Semi-static — valid until product line changes; reviewed annually; new version issued when formulation or performance envelope is updated |
| Primary audience | Customs inspectors, HSE officers, logistics teams, occupational health auditors, EU/US regulatory agencies | QC/QA departments, incoming inspection teams, R&D, food safety auditors, pharmaceutical compliance officers | Procurement engineers, packaging engineers, product designers, application development teams |
| Issuer level | Manufacturer — must carry company seal and authorized signature; rejected if unsigned by most EU and Japanese buyers | Manufacturer QC laboratory — must reference specific batch number, test date, equipment calibration records | Manufacturer technical or product management team — company seal recommended but not legally mandated |
| Update trigger | Composition change, new hazard classification, regulatory change (e.g., OSHA HCS 2024 deadline July 2026, REACH Annex II 2023) | Every production batch — new CoA for every lot; there is no “standard” CoA that covers multiple batches | Product reformulation, new test data, change in raw material source affecting performance, annual review cycle |
| Required by customs | Yes — MSDS/SDS required by US CBP, EU customs, Japanese customs, and most ASEAN customs authorities for chemical goods | Not typically required by customs; however, required by FDA Prior Notice for food-contact desiccants entering the US | Not required by customs; requested by technical buyers and QC teams as part of supplier qualification |
| Required by QC / supplier audit | Requested during supplier onboarding; confirms supplier has a GHS-compliant safety management system | Mandatory for ISO 9001 and HACCP procurement controls; required per batch at goods receipt | Requested during supplier evaluation and product qualification; confirms product meets application performance requirements |
In practice, a complete export documentation package for desiccants must include all three documents: the MSDS establishes regulatory and transport compliance, the CoA demonstrates batch-level quality conformance, and the TDS supports engineering justification for product selection. Requesting only one document leaves gaps that will surface during customs clearance, incoming QC, or customer audit. CEMACO provides all three document types for each desiccant SKU: download the current CoA Silica Gel Batch 2025 Q1 and the Silica Gel TDS 2025 from the documents library, or request the complete package via the quote form.
6. Declaration of Conformity, LoNO, and CFS — When Are They Needed?
Beyond the MSDS, certain markets and applications require supplementary documents to confirm desiccants will not harm the end product. These additional documents are particularly important for desiccants used in food packaging, pharmaceutical packaging, and medical device packaging — sectors where regulatory agencies conduct more rigorous product traceability audits. For general cargo (containers of textiles, wood, electronics), an MSDS alone is usually sufficient at customs. The three most requested supplementary documents are:
- Declaration of Conformity (DoC): Required when desiccant is placed in the same packaging as food, beverages, or children's products for export to the EU — confirming compliance with EC 1935/2004 and EC 2023/2006. CEMACO provides DoC in English for food-grade white silica gel and clay upon request.
- Letter of No Objection (LoNO) / Letter of Guarantee: Requested by US FDA or Japanese pharma buyers to confirm desiccant contains no prohibited substances and will not affect drug stability. Not standardized by law — it is a supplier commitment letter with company seal and authorized signature.
- Certificate of Free Sale (CFS): Common in ASEAN markets (Indonesia, Philippines, Thailand) and some African markets. Issued by the Vietnamese government (Ministry of Industry and Trade or Food Safety Authority) confirming the product is freely marketed in Vietnam. CEMACO assists with CFS procedures when required.
See companion flagship article: Container Rain — The Complete Guide to Anti-Condensation in Containers for documentation requirements in container export shipments.
7. Top 5 MSDS Errors at Customs
- Using an outdated pre-GHS format (pre-2012): Old MSDS may have 9 sections or 16 sections in the wrong GHS order. The US (from 2016) and EU (from 2023) do not accept the old format. Check: does Section 2 read "Hazard(s) Identification" in GHS order? Are GHS pictograms and H/P statements present?
- Missing CAS Number in Section 3: Some old MSDS documents list only trade names without CAS numbers. US CBP and EU customs require CAS numbers. Silica gel must show
7631-86-9; clay must show1302-78-9. Missing CAS = shipment held for clarification. - Wrong UN/Class in Section 14: Most common with CaCl₂ — declaring UN 1453 Class 5.1 for commercial desiccant blends when they are actually Not Regulated. Incorrect Class 5.1 declaration triggers Group III special packaging requirements, hazmat labels, and unnecessarily high freight costs.
- MSDS without company seal or signature: Many EU and Japanese importers reject unsigned, unsealed MSDS documents. Not a strict GHS legal requirement but standard B2B practice. An unsigned PDF MSDS is considered "unverified."
- No target-language version of the MSDS: For EU markets (especially Germany, France, Italy, Poland), an English-only SDS is technically not compliant with REACH Article 31. The EU importer is responsible for translation, but in practice many buyers ask the supplier to provide the official translated version. See ECHA REACH Guidance on SDS.
8. MSDS Download Table by CEMACO Product
| Document | Applicable SKUs | Key Content | Download |
|---|---|---|---|
| MSDS Silica Gel 2025 (v4.0) | All silica gel SKUs (white Type A/B, orange) | 16 GHS sections, CAS 7631-86-9, emergency phone, EN/VI bilingual | Download MSDS Silica Gel |
| MSDS Clay Desiccant 2025 (v3.0) | Montmorillonite clay 30g, 50g, 500g | 16 GHS sections, CAS 1302-78-9, no SVHC, food-grade statement | Download MSDS Clay |
| TDS Silica Gel 2025 | Silica gel 1g–1,000g | Adsorption isotherms, surface area, particle size, operating temperature | Download TDS Silica Gel |
| CoA Silica Gel Batch 2025-Q1 | White Type A silica gel (Q1/2025 batch) | SiO₂ 99.2%, moisture absorption RH50%: 18.5g/100g, pH 5.8, mfg date 15/02/2025 | Download CoA Q1/2025 |
| ISO 9001 Certificate | All CEMACO products | Valid through 2026, scope: manufacture and supply of desiccant packets | Download ISO 9001 |
| HACCP Certificate | Silica gel and clay for food use | HACCP hazard analysis, CCPs, control limits — FDA/EU compliant | Download HACCP |
See also: Silica Gel Complete Guide 2026 for full technical specifications and applications across all SKU types.
9. FAQ — Frequently Asked Questions About Desiccant MSDS for Export
1. How often does a silica gel MSDS need to be updated?
Under REACH Annex II and OSHA HCS 2012, an SDS must be updated immediately when there are significant changes to composition, health hazards, or new regulatory information. The international B2B norm is to review every 3 years if no changes occur. The new effective date must be stated in Section 16.
2. Can one MSDS cover all silica gel SKUs?
Yes, if all SKUs share the same chemical composition (amorphous SiO₂ ≥99%, no cobalt, same raw material supplier). An MSDS is issued at the product-type level, not per SKU. However, if one SKU contains cobalt indicator (blue type), a separate MSDS is required because the GHS classification differs significantly.
3. How is an MSDS different from a CoA when a customer asks for documents?
An MSDS describes chemical safety and is static (only changes when composition changes). A CoA contains actual test results for each production batch — it changes with every batch. Customs typically requires an MSDS; the QC/R&D team typically requires a CoA. Procurement departments often need both when onboarding a new supplier.
4. Does silica gel require REACH registration for EU export?
Under REACH, if SiO₂ (amorphous) is imported into the EU above 1 tonne/year, the EU importer (or a "Only Representative" appointed by the non-EU manufacturer) is responsible for ECHA registration. Vietnamese exporters do not register directly with ECHA — that is the EU importer's responsibility. However, the Vietnamese exporter must provide the EU importer with: full chemical composition data, CAS numbers, SDS, and any substance identity information. Without this data, the EU importer cannot complete their REACH registration dossier. CEMACO provides all required substance identity data as part of the technical documentation package — see the TDS Silica Gel 2025 for full composition data.
5. What additional documents does Japan require beyond the MSDS?
Japan requires SDS in Japanese (JIS Z 7253:2019). For food-chain desiccants, compliance with Japan's Food Sanitation Act (食品衛生法) is required — desiccants must not react with or migrate into food through packaging. Many Japanese importers also require migration testing (溶出試験) per Japanese standards, particularly for desiccants packed in the same box as food products. Additionally, Japan's CSCL 2023 amendment means importers must maintain a formal chemical substance management record for each product. CEMACO can assist by providing detailed substance identity information (SiO₂ purity, particle size, surface area from TDS) and by connecting customers with a Japanese chemical registration consultant. Contact CEMACO hotline 0983 929 232 or see Food-grade desiccant FDA and food safety for related guidance.
6. Is an MSDS sufficient to export to the United States?
An MSDS/SDS is mandatory but not sufficient on its own. Full US customs documentation includes: Commercial Invoice + Packing List + Bill of Lading + SDS (if requested by CBP) + Certificate of Origin (Form E under USFTA) + FDA Prior Notice (if food-contact). For food-contact desiccants, FDA GRAS confirmation is also needed — see FDA 21 CFR desiccant food use.
7. Does clay desiccant need a separate MSDS from silica gel?
Yes. Clay (bentonite/montmorillonite, CAS 1302-78-9) and silica gel (CAS 7631-86-9) are chemically distinct and require separate MSDS documents. Download the CEMACO Clay MSDS 2025 from the documents page. See also Silica Gel vs Clay Desiccant Comparison.
8. If we change raw material suppliers, does the MSDS need to be redone?
It depends on the extent of change. If the new raw material has the same CAS, same purity, same impurity profile — no new MSDS is needed, but Section 16 should note the supplier change. If new impurities appear or component percentages change by >5%, Sections 3 and 11 must be updated. CEMACO's ISO 9001 Change Control process requires this assessment for any raw material substitution.
9. Does an EU Declaration of Conformity replace the MSDS?
No. A DoC (per EC 1935/2004) confirms the product is safe for food contact — it is a Food Contact Material fitness declaration. An MSDS is an occupational safety and transport document for customs and workplace HSE. Both serve different purposes and both are required for EU food export. See EC 1935/2004 — EU desiccant food contact standard.
10. How quickly can CEMACO provide an MSDS after an order?
The current MSDS (latest version) is available immediately — download directly at the documents page or receive via email within 30 minutes of leaving your contact information. A batch-specific CoA is provided together with the delivery note — typically within 1–2 business days after batch picking.
11. Can cobalt blue silica gel be exported to the EU?
Technically yes, but cobalt chloride is an SVHC under REACH. Many EU importers proactively refuse cobalt blue silica gel to avoid compliance risk. CEMACO recommends switching to orange (cobalt-free) or white Type A silica gel for EU and Japanese markets. See: How silica gel color indicators work.
12. What is the correct HS code for desiccant shipments?
Standard HS code classifications for desiccant exports:
- Silica gel desiccant (packaged): HS 3824.99 (Chemical products NEC). Some customs authorities classify under 2811.22 depending on purity declaration.
- Clay/Bentonite desiccant: HS 2508.10 (Bentonite). Activated clay may use 3824.99.
- Calcium chloride desiccant: HS 2827.20 (Calcium chloride). Packaged formulations may use 3824.99.
Correct HS code classification also affects whether Certificate of Origin (C/O) requirements apply. For Vietnamese-origin goods under the ASEAN-Australia-New Zealand FTA or the EVFTA (EU-Vietnam Free Trade Agreement), C/O Form E or Form EUR.1 respectively can be used to reduce import duty at destination — but the C/O must match the declared HS code exactly. CEMACO provides recommended HS codes and English commodity descriptions for each SKU on request. Contact Ms. Yen Nhi at 0948 100 210 (Zalo) for container export documentation support. Full product specs: Silica Gel Complete Guide 2026 and Silica vs Clay vs CaCl2 Comparison.
10. Regulatory Landscape: Key Changes in 2025-2026
Global chemical regulations are evolving. These updates directly affect Vietnamese desiccant exporters:
US: OSHA HCS 2024 Update (GHS Rev.7)
OSHA published the HCS 2024 final rule in May 2024, aligning US standards with GHS Revision 7 effective July 2026. Key changes include tightened Section 3 disclosure requirements and updated SDS language. For amorphous silica gel and clay, GHS classification remains "Not classified" - but SDS format must be updated to the new template before the 2026 deadline. Reference: OSHA Hazard Communication Standard.
EU: REACH Annex II - Regulation 2020/878 in Force
EU Regulation 2020/878 (amending REACH Annex II) has been mandatory since January 1, 2023. SDS for mixtures supplied to professional EU users now must include a UFI (Unique Formula Identifier) in Section 1 to enable EU Poison Centre notification. The EU importer should confirm their UFI notification obligations for desiccant products. See: ECHA REACH Guidance on SDS.
Japan: CSCL 2023 Amendment and Self-Management
Japan amended the Chemical Substances Control Law in April 2023, introducing stricter self-management obligations for industrial chemicals. Japanese importers of desiccants for industrial use now need more comprehensive hazard records. An SDS updated to JIS Z 7253:2019 (GHS Rev.7) format is essential. CEMACO can connect customers with a qualified Japanese-language SDS translation partner.
Vietnam: Circular 32/2017/TT-BCT
Domestically, CEMACO complies with Circular 32/2017/TT-BCT (Ministry of Industry and Trade) governing MSDS in Vietnamese workplaces. All desiccant products supplied within Vietnam include a Vietnamese-language MSDS. Companies using desiccants in manufacturing must maintain MSDS records and conduct worker chemical safety training under Law on Chemicals No. 06/2007/QH12. For food facilities, MSDS records are also required under HACCP and GMP audits. See CEMACO certifications at the certificates page and food-grade requirements at FDA 21 CFR desiccant food use.
Request Full MSDS + CoA + TDS Document Package — Free
CEMACO Saigon provides complete GHS/OSHA/REACH-compliant technical documentation for all desiccant SKUs: silica gel, clay, and CaCl₂ powder. All documents carry the company seal and are signed by the authorized Quality Manager, meeting the requirements of EU importers, US CBP, and Japanese customs. Documentation is available in bilingual English-Vietnamese format. ISO 9001 and HACCP certificates are valid through 2026. For custom documentation requirements (third-party language, specific SDS format, supplementary testing), contact our technical team via hotline or through the quote form below.
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