A New Year: Navigating Canada and US SDS Compliance

For years, regulatory bodies in Canada and the United States have worked through the Regulatory Cooperation Council (RCC) to align the classification and labeling of workplace chemicals. The goal is a seamless "one product, one SDS" approach for North America.

However, as of December 2025, a significant gap has opened in the compliance timelines of the two nations.

Canada: The Transition is Over

As of December 15, 2025, the transition period for the amended Hazardous Products Regulations (HPR) in Canada has officially ended.

In late 2022, Canada updated WHMIS to align with the 7th Revised Edition of the GHS (and certain elements of the 8th). Health Canada provided a three-year window for manufacturers, importers, and distributors to update their Safety Data Sheets and labels. That window is now closed.

What this means for your Canadian SDSs:

• Full Compliance Required: All SDSs and labels for hazardous products sold or imported into Canada must now meet the amended HPR requirements.

• GHS 7 Standards: This includes new hazard classes (such as "Chemicals Under Pressure"), updated definitions for Flammable Gases, and more specific requirements for Substantial Precautions.

• Strict Bilingual Requirements: Despite alignment efforts, Canada maintains strict requirements for SDSs to be available in both English and French.

According to WHMIS.org, an SDS is not a static document. If you are still using "transitional" SDSs that were compliant under the old 2015 rules, you are now technically out of compliance in the Canadian market.

The United States: Still in the Transition Phase

While Canada has reached the finish line, the United States is still in the middle of its marathon.

OSHA published the final rule to update the Hazard Communication Standard (HCS) to align with GHS Revision 7 in May 2024. However, the U.S. compliance dates are staggered much further out:

• Chemical Manufacturers and Importers: Have until January 19, 2026, to comply with the updated HCS for substances, and until July 19, 2027, for mixtures.

• Distributors and Employers: Have even longer (into 2028) to ensure their labeling and workplace programs are fully updated.

This means that for at least the next year, a "standard" U.S. SDS may not be sufficient for the Canadian market, as the U.S. version might still be following the older HCS 2012 (GHS Rev 3) standards.

The "Alignment" Myth: Navigating Variances

Even when both countries eventually fully adopt GHS Revision 7, they will not be identical. The Health Canada Regulatory Cooperation Council explicitly identifies several variances that remain between the two countries.

These variances include:

• Bilingual Requirements: Canada requires French and English; the U.S. does not.

• HMIRA Claim Processes: The process for protecting trade secrets (Confidential Business Information) differs significantly between Health Canada and OSHA.

• Specific Hazard Classes: Canada has retained specific requirements for certain hazard classes (like Biohazardous Infectious Materials) that the U.S. does not recognize.

Don't Let Your Compliance Lapse

With Canada’s full implementation now in effect, the "wait and see" approach is no longer an option. If you are shipping products into Canada using SDSs authored before 2023, or using U.S.-based templates that haven't been updated for the new HPR amendments, you are at risk of border delays and regulatory fines.

At SDSWriter.com, we specialize in navigating these specific cross-border variances. We ensure your documents are not just "GHS compliant," but specifically tailored to meet the strict December 2025 Canadian requirements while preparing you for the upcoming U.S. deadlines.

Is your SDS library ready for 2026?