Suppliers selling or importing hazardous products for Canadian workplaces must provide a safety data sheet that complies with the Hazardous Products Regulations (HPR). The SDS must be in English and French, follow the 16-section format in Schedule 1 of the HPR, and be updated when significant new hazard information becomes available.
WHMIS is Canada's implementation of GHS. While a US HazCom 2024 SDS can serve as a starting point, it does not meet WHMIS requirements until it addresses Canadian-specific elements: language, identification of the Canadian supplier in Section 1, ingredient disclosure and confidential business information, and update timing.
Last reviewed November 7, 2026. This page provides information only and does not constitute legal advice.
Who WHMIS applies to
Supplier rules apply to anyone selling or importing hazardous products for use, handling, or storage in a Canadian workplace, including Canadian manufacturers, distributors, and importers. US manufacturers shipping to Canada typically rely on their Canadian importer or distributor; however, Canadian customers often request a compliant WHMIS SDS directly from the manufacturer.
The legal basis has three layers:
- Hazardous Products Act (HPA): sections 13 and 14 prohibit selling or importing a hazardous product unless the supplier has an SDS and label that meet the regulations.
- Hazardous Products Regulations (HPR, SOR/2015-17): the classification criteria, SDS content, label content and exemptions.
- Federal, provincial and territorial occupational health and safety laws: the employer side of WHMIS, including worker training and keeping SDSs accessible.
Health Canada amended the HPR in December 2022 to align with the 7th revised edition of the GHS and parts of the 8th. The three-year transition period ended December 14, 2025. Health Canada will focus on compliance promotion until November 19, 2027, which is the US deadline for mixtures, and will then enforce requirements based on risk.
Certain products are excluded from HPA supplier rules, including consumer products, cosmetics, drugs, food, explosives, pest control products, and hazardous waste. These are regulated under other legislation.
English and French
Every WHMIS SDS must be available in both English and French. Health Canada accepts two ways to do this:
- One bilingual SDS. A single document that contains every section in both languages, for example English and French side by side in two columns, or the full English SDS followed by the full French SDS in the same file.
- Two separate SDSs, sent together. A complete English SDS and a complete French SDS. The customer must receive both at the time of sale, not just the language they asked for.
Either way, both versions must say the same thing: same classification, same values, same revision date. An SDS in only one language does not meet the requirement, regardless of the province of sale.
Supplier labels must also be bilingual, durable, and legible. When emailing an SDS, CCOHS specifies that the document must be attached; providing only a website link is insufficient.
The French version is a regulatory document, not a marketing translation. Hazard and precautionary statements must use standard French wording, and all values, such as concentrations, flash point, and exposure limits, must match the English version exactly.
WHMIS SDS vs. US HazCom 2024 SDS: what changes
Both systems use the same 16 section headings in the same order. Differences are found in specific details. Sections not listed here follow the same GHS content in both countries.
| SDS section | WHMIS (Canada) | HazCom 2024 (US) |
|---|---|---|
| Language | English and French: one SDS with both languages, or an English SDS and a French SDS sent together | English (other languages may be added) |
| 1. Identification | Initial supplier identifier: name, address and phone of the Canadian manufacturer or importer. A Canadian distributor may substitute its own details; an importer using the product in its own workplace may keep the foreign supplier's details. Emergency number must state any restrictions, such as hours, and the language if not English or French. | Name, address and phone of the US chemical manufacturer, importer or other responsible party, plus an emergency number |
| 2. Hazard identification | WHMIS hazard classes, including Biohazardous Infectious Materials, which the US standard does not have | HazCom 2024 hazard classes |
| 3. Composition | All hazardous ingredients above their cut-off must be listed, whether or not they drive the mixture's classification. Trade-secret concentrations use the same 13 prescribed ranges as HazCom 2024. Withholding a chemical identity needs a claim to Health Canada. | Hazardous ingredients above cut-offs. Trade-secret concentrations use OSHA's 13 prescribed ranges. No filing with OSHA. |
| 9. Physical and chemical properties | Item list revised in the 2022 amendments | Item list revised in HCS 2024 |
| 12–15. Ecological, disposal, transport, regulatory | Headings required; content may be omitted (HPR s. 4(2)) | Headings required; OSHA does not enforce the content |
| 16. Other information | Date of the latest revision | Date of preparation or last revision |
For details on each section, see The 16 Sections of an SDS.
Supplier labels
The supplier label includes the same hazard information as SDS Section 2, provided in both English and French:
- Product identifier, matching the SDS
- Initial supplier identifier
- Pictograms
- Signal word
- Hazard statements
- Precautionary statements
- Supplemental label information, where required
Labels must be durable and legible. If a label is lost or damaged, the product must be relabelled before sale or import. An English-only US label does not meet this requirement, even if the hazard information is identical.
Keeping a WHMIS SDS current
A WHMIS SDS must be accurate at the time of sale or import. If a supplier becomes aware of significant new data, such as information that changes a classification, HPR section 5.12 establishes two timelines:
| What changes | Window | What to send meanwhile |
|---|---|---|
| SDS | 90 days after the new data becomes available | The existing SDS plus a written document listing the changes and the date the data became available |
| Label | 180 days after the new data becomes available | The existing label plus a written document listing the label changes and the date |
Once the window closes, the SDS or label must be updated. HazCom 2024 requires SDS updates within three months and label updates within six months.
The federal HPR no longer requires suppliers to reissue SDSs every three years, unlike WHMIS 1988. However, some provinces and federal workplaces still require employers to obtain an updated SDS every three years, so customers may request them.
Suppliers must also keep true copies of every SDS and label they sell or import, plus sales records, for six years after the end of the year they relate to (HPA s. 14.3).
Confidential business information and concentration ranges
Canada manages trade secrets differently than the US. In the US, there is no filing requirement with OSHA. In Canada, suppliers wishing to withhold confidential business information (CBI) must file a claim for exemption with Health Canada under the Hazardous Materials Information Review Act (HMIRA). Suppliers may claim exemption for the following:
- The chemical identity of a hazardous ingredient
- The concentration of a hazardous ingredient
- The name of a toxicological study that identifies a hazardous ingredient
If a concentration is withheld as a trade secret, HPR sections 4.4.1 and 4.5 specify how it must be disclosed in Section 3:
- Use one of the 13 prescribed ranges, from 0.1–1% up to 80–100%, or a narrower range that falls within one of them.
- If an actual range between 0.1% and 30% does not fit a single prescribed range, two consecutive ranges may be combined.
- Include a statement after the range indicating that the actual concentration or concentration range is withheld as a trade secret.
The 13 prescribed ranges are the same as in HazCom 2024; Canada and the US aligned them. The difference is the process: in Canada, the trade-secret claim is filed with Health Canada, while in the US nothing is filed with OSHA. For US requirements, refer to SDS Section 3 concentration ranges under HazCom 2024.
All disclosures must reflect the most hazardous concentration of each ingredient (HPR s. 4.4).
How Valenc handles WHMIS
Valenc creates the WHMIS SDS from the same product record as your US SDS, allowing you to maintain a single formulation rather than separate documents.
- Canadian HPR format. Valenc’s rules engine classifies products under WHMIS criteria, including Biohazardous Infectious Materials, and applies the HPR section structure with Canadian supplier details in Section 1.
- Bilingual SDSs. Valenc generates English and French versions from a single record. Hazard and precautionary statements are sourced from a curated phrase library, ensuring both languages have consistent classification and values.
- Bilingual supplier labels. WHMIS labels are generated from the same classified record as the SDS, in both English and French.
- One change, every version flagged. When a formulation or rule changes, all affected US and Canadian SDSs and labels are flagged for review.
- Your approval before publication. Your team reviews and approves each SDS before release.
View supported regions and languages, or request a demo using one of your products.
Frequently asked questions
Can I use my US SDS in Canada?
Not without modification. A HazCom 2024 SDS must include French, the Canadian initial supplier in Section 1, Canadian ingredient disclosure and CBI wording in Section 3, and a review of all classifications against WHMIS criteria.
Does a WHMIS SDS have to be bilingual?
Yes. You may provide a single SDS containing both English and French, or separate complete English and French SDSs sent together. The customer must receive both languages, and both versions must match in content.
How often does a WHMIS SDS need to be updated?
Update whenever significant new data becomes available. Suppliers have 90 days to update the SDS and 180 days to update the label, and must provide a written list of changes in the interim. There is no federal three-year reissue requirement for suppliers.
Are Sections 12 to 15 required on a WHMIS SDS?
The section headings are required. Under HPR s. 4(2), the content of Sections 12 to 15 may be omitted.
What is the Hazardous Products Regulations?
The federal regulation (SOR/2015-17) under the Hazardous Products Act that sets WHMIS classification criteria and the SDS and label requirements for suppliers.
How do I protect a trade secret on a WHMIS SDS?
File a claim for exemption with Health Canada under HMIRA, then disclose the concentration using a prescribed range and include the required trade-secret statement.
Who is the initial supplier on a WHMIS SDS?
The Canadian manufacturer or importer. A Canadian distributor may substitute its own details.
Sources
- Hazardous Products Act, sections 13–14.3, Justice Laws
- Hazardous Products Regulations (SOR/2015-17), Justice Laws: s. 4(2), 4.4, 4.4.1, 4.5, 5.12
- Supplier hazard communication requirements under WHMIS, Health Canada
- Amended Hazardous Products Regulations, Health Canada
- Exemptions for confidential business information: About, Health Canada
- WHMIS: Safety Data Sheet (SDS), CCOHS
See a WHMIS SDS built from one of your own products, in English and French, from the same record as your US SDS.
