Certificates and documentation: what should come with surplus raw material?

What documents should come with surplus raw material?

The complete set is shorter than people expect. Most materials need five or six documents, and which ones depend on the sector and whether the material is hazardous.

If you're selling, assemble this set before you list. If you're buying, ask for it before you negotiate. An enquiry that stalls two weeks in because a document can't be produced has wasted both parties' time.

Does the document describe the site, the product, or the batch?

This is the single distinction that resolves most documentation arguments, and it is almost never drawn explicitly.

The failure mode is substitution across tiers. A seller offers a GMP certificate when asked for batch evidence, or a Technical Data Sheet when asked for a specification. Neither is dishonest, exactly. Both leave the buyer unable to qualify the material, because a document from a wider tier can't answer a narrower question.

What is a Certificate of Analysis, and what should be on it?

A Certificate of Analysis is the manufacturer's record of the tests run on one specific batch, alongside the specification each result had to meet. It's the most important document in the set, because it is the only one that speaks to the goods actually in front of you.

• The material name, and where relevant the INCI name, CAS number or grade.
• The batch or lot number, which must match what is physically printed on the drum, sack or pallet.
• The date of manufacture, and the expiry or retest date.
• Each parameter tested, the test method used, the measured result, and the acceptance range.
• The manufacturer's name and site, and an authorising signature or quality release.

The batch number is the load-bearing field. Everything else on the certificate is a claim about a quantity of material, and the batch number is what ties that claim to the goods. If they don't match, the document is evidence about somebody else's material.

A Certificate of Analysis is evidence about one batch and nothing else. It doesn't describe the product line in general, and it doesn't transfer to a different batch of the same material.

Certificate of Analysis vs Certificate of Conformance: what is the difference?

A Certificate of Analysis reports measured test results. A Certificate of Conformance declares that the goods meet an agreed requirement, without necessarily showing the measurements behind it. One gives you data, the other gives you someone's word.

A third term, Certificate of Compliance, is used interchangeably with conformance in most Australian trade, though strictly it means satisfying a regulatory obligation rather than a contractual one. In practice, ask which of the three you're being offered, because a quality system that requires data won't accept an attestation.

How current does a Safety Data Sheet have to be?

Under Australia's model work health and safety regulations, a manufacturer or importer of a hazardous chemical must review and update the Safety Data Sheet at least every five years, and the sheet must state when it was last reviewed. The model regulations are only law where a jurisdiction has adopted them: Victoria has not, and Victorian duties sit under the Occupational Health and Safety Act 2004 and its regulations instead. The five-year practice is the same either way.

Five years is a floor rather than a schedule. The sheet has to be updated sooner if the hazard picture changes: new toxicological data, a reclassification, a change in the physical hazards. A sheet dated six years ago tells you the manufacturer or importer has not met their review duty. That duty is theirs, not yours: a surplus seller who is neither is not in breach for holding an old sheet, but they are expected to supply the current one. I've been sent plenty of six-year-old sheets, and it says more about the holder's records than about the material.

The Safety Data Sheet follows a fixed sixteen-section structure set by the Globally Harmonized System, so the same information sits in the same place on every supplier's version. The older term Material Safety Data Sheet, or MSDS, refers to the pre-GHS format and has been superseded. Be careful with the title alone, though: some suppliers, particularly outside Australia, still label a fully compliant sixteen-section document an MSDS. Judge it on the sections and the revision date rather than the words on the front page.

One thing the Safety Data Sheet isn't: batch evidence. It describes the substance, not the consignment, so it is reused across every batch and proves nothing about the specific material on offer.

Technical Data Sheet or specification: which one governs?

The specification governs. This trips up more purchases than any other documentation question, because the two documents look similar and one is much easier to obtain.

A Technical Data Sheet is descriptive. It tells a formulator how the material typically behaves: appearance, solubility, pH, recommended use levels, typical analytical values. Those typical values characterise the product line, not any particular delivery.

A specification is contractual. It sets the acceptance limits a delivered batch must satisfy, and it is the document the Certificate of Analysis is read against. A batch can sit comfortably within typical values and still fall outside the limits your own specification requires.

So the practical question is never whether the seller has a Technical Data Sheet. It's whether their specification is the one you work to.

Which certifications matter, and what do they actually cover?

Site and scheme certifications tell you the seller runs a controlled operation with traceability and record-keeping. That makes their batch documentation more likely to be complete. It isn't a substitute for that documentation.

• Good Manufacturing Practice covers premises, equipment, process control, documentation and recall capability. ISO 22716 is the version written for cosmetics.
• ISO 9001 is a general quality management standard. Useful context, but it says nothing sector-specific.
• HACCP, or hazard analysis and critical control points, underpins most food manufacturing controls in Australia.
• Therapeutic goods, including listed and registered medicines, sit under the Therapeutic Goods Administration instead.
• For organic claims the common marks are Australian Certified Organic and COSMOS. Both certify the operation and the input chain rather than a single batch.
• Halal, kosher, vegan and cruelty-free schemes cover ingredients and process. They usually attach to specific certified products, not to everything the site makes.
• SEDEX and similar ethical audits look at social and environmental conditions. They say nothing at all about material quality.

The trap with scheme certifications is scope. A site can hold organic certification and manufacture non-organic products alongside it, and the certificate covers the certified lines rather than the whole facility. We hold several of these ourselves, and I still check the scope statement on other people's before I assume anything. Ask what the certificate actually covers.

What documentation do dangerous goods need?

If a material is classified as dangerous goods, transport documentation is a legal requirement rather than a courtesy, and the duty falls on the consignor — the party sending the goods.

Under the Australian Dangerous Goods Code, the consignor must classify the material correctly, pack and mark it accordingly, inform the carrier, and provide a compliant transport document showing the UN number, proper shipping name, class and division, and packing group. Edition 7.9 of the Code has been mandatory since 1 October 2025, though the Code takes effect through state and territory legislation and the NTC notes commencement in some jurisdictions may be later.

For a surplus sale this matters twice over. The seller carries the classification duty and can't delegate it to a marketplace or a carrier. And the buyer needs to confirm their carrier is licensed for the declared class before making an offer, because that materially narrows the field of available carriers and can change the freight cost.

What if a document is missing?

Sometimes a document genuinely doesn't exist. A material may not be hazardous and so has no Safety Data Sheet. A commodity input may never have carried a batch certificate. That is a legitimate position, and it is different from a document that has been lost.

The distinction to insist on is between "not applicable" and "not available". Not applicable means the document was never required. Not available means the record existed and the chain has broken, which is the situation that destroys value — provenance once lost usually can't be reconstructed, only replaced with fresh testing.

If you're selling, say which of the two applies. We stamp not applicable rather than leave a blank, because a silent omission makes a buyer wonder what else is missing, and they're right to wonder.

On Surply, documents are attached to the listing rather than supplied on request, and publication is fail-closed: where extraction of a document is incomplete, stale or unreviewed, the buyer sees nothing rather than a substitute. A wrong document is worse than a missing one, because a missing one makes you ask.

Common questions

Is a Certificate of Analysis the same as a Certificate of Conformance?

No. A Certificate of Analysis reports the measured test results for one batch against its acceptance ranges. A Certificate of Conformance is a supplier declaration that goods meet an agreed requirement, without necessarily showing the underlying data. Many transactions require both. A quality system that needs measured data won't accept an attestation in its place.

How long is a Safety Data Sheet valid in Australia?

Manufacturers and importers of hazardous chemicals must review and update a Safety Data Sheet at least every five years under Australia's model work health and safety regulations, and the sheet must state its last review date. It must be updated sooner if the hazard information changes. The duty sits with the manufacturer or importer rather than with a downstream seller, whose obligation is to supply the current sheet. Victoria applies its own OHS framework.

Does a GMP certificate prove a batch meets specification?

No. Good Manufacturing Practice certification describes the facility and its quality systems: premises, process control, documentation, recall capability. It makes complete batch records more likely, but it isn't evidence about any individual batch. Only a Certificate of Analysis carrying the matching batch number does that.

Can I use a Technical Data Sheet instead of a specification?

Not for qualification. A Technical Data Sheet is descriptive and reports typical values for a product line. A specification is contractual and sets the acceptance limits a delivered batch must meet. A batch can fall within typical values while failing the specification you actually work to, so the two aren't interchangeable.

What is the difference between an MSDS and an SDS?

The Material Safety Data Sheet is the older, pre-GHS format. The Safety Data Sheet replaced it and follows a fixed sixteen-section structure defined by the Globally Harmonized System, so information sits in the same place on every supplier's version. Being offered an MSDS generally indicates the documentation has not been maintained.

Who is responsible for classifying dangerous goods?

The consignor, meaning the party sending the goods. Under the Australian Dangerous Goods Code, currently Edition 7.9, the consignor must classify the material, pack and mark it, inform the carrier and supply a compliant transport document with the UN number, proper shipping name, class and packing group. This duty can't be delegated to a carrier or a marketplace.

Sources and references

• Safe Work Australia — Preparing safety data sheets
• Safe Work Australia — Using safety data sheets
• National Transport Commission — Australian Dangerous Goods Code
• Therapeutic Goods Administration
• Food Standards Australia New Zealand