The cylinder label does not match the safety data sheet: what to do

Quick answer

If the cylinder label and the safety data sheet say different things, do not use the cylinder until the discrepancy is resolved in writing. The reason is not bureaucratic: the label and the sheet are the two documents every later technical decision rests on, from the safety class and working pressure to the CO2 equivalent calculation and what goes into the equipment record.

The law requires them to agree. Article 18(1) of Regulation (EC) No 1272/2008 (CLP) says the term used to identify the substance or mixture on the label shall be the same as the one used in the safety data sheet. Article 25(3) of the same regulation forbids supplemental information that contradicts or casts doubt on the mandatory label elements.

The practical path has four moves: stop, segregate, document, write to the supplier. Only after the supplier's answer do you decide whether the cylinder is released, returned, or treated as a non-conforming product.

What the law requires to match

The two documents come from different legal sources, but they overlap exactly where it matters.

The label on a fluorinated greenhouse gas container is required by Article 12(1)(g) of Regulation (EU) 2024/573 and must carry, under Article 12(3):

• an indication that the product contains fluorinated greenhouse gases;
• the accepted industry designation for the gases concerned or, if there is none, the chemical name;
• the quantity expressed in weight and in CO2 equivalent, and the global warming potential of those gases.

Article 12(4) adds the form: the label shall be clearly legible and indelible, placed either adjacent to the service ports or on the part of the product that contains the gas, and written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied.

Implementing Regulation (EU) 2024/2174 fixes the detail: Article 1(1) requires the information to stand out clearly from the background and be clearly readable; Article 1(2) requires the label to remain securely in place and legible under normal operational conditions throughout the whole period during which the product contains the gas; Article 1(3) requires the text "contains fluorinated greenhouse gases"; Article 1(4) requires the weight in kilogram or gram and the CO2 equivalent in tonne, using the GWP values in the relevant column of Annexes I, II and III; Article 1(6) puts the information in the supplemental information section of the CLP label where the container is also labelled under CLP; and Article 1(7) sets the wording for reclaimed and recycled gases.

The safety data sheet follows the format set by Regulation (EU) 2020/878. The sections that enter the comparison are:

• Subsection 1.1 — the product identifier, which is provided as provided on the label, in the official languages of the Member State where the product is placed on the market.
• Subsections 2.1 and 2.2 — the CLP classification and the label elements: pictograms, signal word, hazard statements and precautionary statements.
• Section 3 — the composition. For mixtures, concentrations are given as exact percentages in descending order by mass or volume, or as ranges of percentages in the same order.
• Section 9 — physical and chemical properties, which have to be consistent with the classification.
• Section 14 — transport information.

For the general list of papers travelling with a cylinder, see the guide on documents with a refrigerant cylinder, and for reading the sheet section by section, the guide on how to read a safety data sheet.

The kinds of discrepancy and what each one means

Not every discrepancy carries the same weight, but none of them is solved by ignoring it. The table shows what each kind puts in doubt.

The arithmetic check in the fourth row is the quickest and catches most data errors: the quantity in tonnes of CO2 equivalent is the net mass in kilograms multiplied by the GWP and divided by 1 000. If the result does not match the label, one of the three figures is wrong.

The decision path, step by step

The order matters. The first move is always to stop, not to pick up the phone.

Before you conclude: version, relabelling, retrofit

A fair share of the discrepancies flagged at goods-in are not discrepancies at all, but comparisons between documents from different moments. Three situations explain most cases.

• Old sheet, new product. Point 0.2.5 of Annex II to Regulation (EU) 2020/878 requires the date of compilation on the first page and, for revised versions, the indication Revision with the date together with one or more indications of which version is replaced, such as version number, revision number or supersedes date. Changes are brought to the recipients' attention in section 16. Check first whether you are holding the latest version.
• Refilled container. Article 12(6) of Regulation (EU) 2024/573 requires refilled containers to be relabelled, where relevant, with the updated information referred to in the first subparagraph of Article 12(3). A label left over from the previous filling is not a valid label.
• Retrofitted equipment. The last subparagraph of Article 12(3) requires that where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, they shall be relabelled with updated information. The same logic explains why an old nameplate on a system does not tell you what is in it today.

If the label is simply damaged or illegible, the problem is form, not content: Article 12(4) requires a clearly legible and indelible label, and Article 1(2) of Regulation (EU) 2024/2174 requires it to stay legible throughout the period the product contains the gas. A destroyed label is reinstated with the correct information before the cylinder is made available onwards. See also the guide on transporting cylinders for the legibility requirement in transit.

When it is more than a clerical error

Some patterns raise questions that are no longer solved between you and your supplier. This is not about accusing anyone; it is about recognising the point at which the matter has to go further, to the competent authority.

• The designation on the label does not match the composition declared in section 3 of the sheet, and no version of the documents explains the difference.
• The GWP stated does not correspond to the annex value for the substance indicated, and the CO2 equivalent is calculated on that basis.
• The label mentions reclamation, but the batch number or the name and address of the reclamation facility in the Union required by Article 12(7) are missing.
• The hazard elements on the label contradict the classification in section 2 of the sheet in a way that would change how the product is handled.
• The supplier cannot state the origin of the batch, or the answers change between messages.

The guide on counterfeit and illegal refrigerant covers the specific signals and the reporting channels. If the cylinder also has physical problems on delivery, see the guide on a damaged or suspicious cylinder on delivery.

What stays on file once it is resolved

A discrepancy file that is properly closed keeps four things together: the evidence of the finding, the correspondence with the supplier, the corrected document and the decision taken.

• The sales record. Article 7(3) of Regulation (EU) 2024/573 obliges undertakings supplying Annex I or Section 1 Annex II gases to record each purchaser's certificate number and the respective quantities, for at least 5 years, and to make the records available on request to the competent authority or to the Commission. If the batch went onwards, that record shows the route.
• The equipment record. If the gas was after all charged into equipment subject to leak checks, Article 7(1) requires the quantity and type of gas added to be recorded, and point (d) also requires whether it was recycled or reclaimed, together with the name and address in the Union of the facility. An uncertain product name makes that entry impossible to complete correctly.
• The corrected documents. The reinstated label or the updated sheet is kept alongside the original version, so that what changed stays visible.
• The internal decision. Who decided on release or return, on what basis and on what date.

For the equipment record side, see the guide on F-gas equipment records. For the rules on selling onwards, see who can buy refrigerant gas.

Goods-in checklist

• The designation on the label is identical to the one in the sheetArticle 18(1) CLP and point 1.1 of Annex II to Regulation (EU) 2020/878.
• The sheet you are comparing is the latest versionDate of compilation on the first page, the revision indication and the version replaced, under point 0.2.5.
• The net mass on the label matches the delivery documentArticle 12(3)(c).
• The CO2 equivalent stands up to an arithmetic checkNet mass in kilograms multiplied by the GWP and divided by 1 000.
• The GWP on the label matches the column in the annexesArticle 1(4) of Regulation (EU) 2024/2174.
• The label carries the fluorinated greenhouse gas indicationArticle 12(3)(a) and Article 1(3) of Regulation (EU) 2024/2174.
• The label language matches the destination Member StateArticle 12(4), second subparagraph, and Article 17(2) CLP.
• The hazard elements on the label match section 2.2 of the sheetArticle 17(1) and Article 25(3) CLP.
• For reclaimed gas, the batch number and the facility are on the labelArticle 12(7).
• If something does not match, the cylinder is segregated and documentedPhotographs, sheet version, delivery document, written request.

Frequently asked questions

Official sources

The label and sheet requirements were read directly in the Official Journal texts. The consistency rule between label and sheet comes from CLP, and the structure of the sheet from the safety data sheet regulation.

Currency of this page and limits of responsibility

General information prepared by EgoLog from Union legislation and official Commission material. It is not legal advice.

Until it is resolved, the cylinder stays closed, segregated and unaltered. Handling gases under pressure is done by competent persons with suitable equipment.