Hazardous Products Regulations alignment with a newer GHS revision

What changed

Health Canada amended the Hazardous Products Regulations (HPR) to align Canada's WHMIS supplier requirements with the 7th revised edition of the GHS, plus selected elements of the 8th revised edition. The amendments were published in Canada Gazette, Part II on 4 January 2023 and came into force on 15 December 2022.

The amended HPR is based on GHS Revision 7 across the board, except for the Chemicals Under Pressure physical hazard class, which was adopted from GHS Revision 8. Other Revision 7 changes include a new hazard category for non-flammable aerosols, new subcategories for Flammable Gases, a new test procedure for Oxidizing Solids, and updated SDS information-element requirements in Schedule 1.

Legal status

This is in force. The 3-year transition period for updating Canadian product classifications, safety data sheets and labels ended on 14 December 2025. Since 15 December 2025, suppliers should no longer rely on the former transition period for products covered by the amended HPR.

Health Canada has said that, after the Canadian transition ended, it will focus on compliance promotion with regulated parties until the end of the aligned US OSHA HCS 2024 compliance date for mixtures — currently 19 November 2027 under OSHA's extended schedule. This is compliance-promotion context, not an extension of Canada's own HPR transition deadline, which has already passed.

Why this needs attention

This is a direct Hazard Communication issue. Companies selling or importing hazardous workplace products into Canada need classifications, SDSs and labels that comply with the amended HPR. The update can affect hazard classification logic, flammable gas categories, Chemicals Under Pressure, SDS information elements, label elements, precautionary statements, ingredient disclosure in mixtures, bilingual English/French compliance, and Canada/US SDS harmonisation.

A US OSHA HCS 2024 SDS cannot be copied automatically into Canada without checking Canadian WHMIS/HPR-specific requirements.

Compliance impact

Treat this as an active compliance baseline:

1. Classification — products must be classified under the amended HPR criteria.
2. SDS — content must follow Canadian HPR requirements, including required information elements.
3. Labels — supplier labels must reflect the applicable Canadian hazard information.
4. Languages — Canadian workplace hazardous product information must be available in English and French where required.
5. Mixture disclosure — hazardous ingredients above relevant cut-off levels must be disclosed under the amended rules.
6. Cross-border products — Canada/US alignment is improved but not identical, so variances must be checked.

Recommended actions

Portfolio screening

• Identify all hazardous products supplied, sold or imported for Canadian workplace use, and confirm whether each has been reclassified under the amended HPR.
• Keep Canada WHMIS classification logic separate from US OSHA HCS and EU CLP logic, and flag aerosols, gases and pressurised products for specific review.

SDS update

• Confirm each Canadian SDS reflects the amended HPR requirements — check Section 2 for correct WHMIS classification and label elements, and Section 3 for mixture ingredient disclosure.
• Review physical hazard information for flammable gases and Chemicals Under Pressure.
• Confirm English and French versions are available and aligned, and archive the previous SDS version alongside the new compliance version.

Label update

• Confirm labels include the correct pictograms, signal word, hazard statements and precautionary statements, with bilingual text where applicable.
• Ensure label classification matches SDS Section 2, and that small-container or special-format labels still meet Canadian requirements.
• Prevent shipment where the label and SDS are inconsistent.

Canada/US harmonisation control

• Compare Canadian HPR requirements with OSHA HCS 2024 and identify allowed variances and country-specific information.
• Don't assume one North American SDS automatically satisfies both jurisdictions — maintain distinct Canada-EN, Canada-FR and US-HCS2024 SDS variants, and track the US transition separately from the (already-passed) Canadian deadline.

Audit readiness

• Keep evidence of classification review, SDS and label approval dates, and bilingual translation review records.
• Record the applicable GHS/HPR version and keep supplier/customer communication logs.
• Train sales, customer service and EHS teams on the post-transition baseline.