WHMIS in 2026: The Transition Is Over — What Full HPR Compliance Means

The short version

The amendments to the Hazardous Products Regulations (HPR) made by SOR/2022-272 — Canada's alignment with the 7th revised edition of the GHS (plus one element of the 8th) — came into force on December 15, 2022, with a three-year transition. That transition ended on December 14, 2025.

Since December 15, 2025, every hazardous product sold or imported for use in a Canadian workplace must have a classification, safety data sheet (SDS) and label (where applicable) that fully complies with the amended HPR. There is no longer any option to rely on the former rules.

"But enforcement only starts in November 2027…"

Health Canada has said it will focus on compliance promotion with regulated parties until the end of the applicable U.S. transition period — a date that moved from July 19, 2027 to November 19, 2027 after U.S. OSHA extended its own Hazard Communication Standard deadline in January 2026. From that date, Health Canada moves to risk-based enforcement.

Read that carefully: it is a posture, not a grace period. The legal obligation has applied since December 15, 2025, and Health Canada retains the authority to compel compliance at any time. Waiting also compounds the work: every non-compliant SDS in circulation is a document you will have to fix anyway, while your workers train on outdated hazard information in the meantime.

What actually changed in the amended HPR

• New physical hazard class: Chemicals Under Pressure (adopted from GHS Rev. 8).
• "Flammable Aerosols" renamed "Aerosols", with a new Category 3 for non-flammable aerosols.
• Flammable Gases Category 1 split into subcategories 1A and 1B; the separate Pyrophoric Gases class was repealed and folded into Category 1A.
• SDS Section 9 (physical and chemical properties) rewritten — new and modified information elements on every SDS.
• A second combustible dust hazard statement option ("May form explosible dust-air mixture").
• Classification fixes: water-activated toxicants, classification of mixtures into subcategories where data allow, corrected Reproductive Toxicity Category 2 criteria.
• Changes to prescribed concentration ranges used to protect confidential business information.

Who must do what

Suppliers (manufacturers, importers, distributors) carry the direct obligation under the Hazardous Products Act: compliant classification, SDS and label for every product sold or imported. Health Canada has also reminded suppliers of an under-appreciated duty: prepare and maintain a true copy of the label and SDS for each product.

HMIRA claimants (confidential business information): SDSs and labels filed with a claim for exemption must comply with the amended HPR. Claimants whose filings were based on the former HPR may be required, on request, to provide a revised SDS or label.

Employers — in Quebec, under the CNESST regime — must ensure the SDSs available in the workplace are the compliant, up-to-date versions, and must retrain workers where hazard information changed (new classes, renamed classes, revised SDS Section 9, new statements). If your SDS library still contains pre-2025 documents from suppliers, now is the time to chase replacements.

Your action checklist

1. Audit your SDS library for documents that predate the amended HPR or still show former classifications.
2. Request updated SDSs from suppliers for anything non-compliant — and document the request.
3. Check your own labels if you import or distribute: label elements must match the amended classification.
4. Refresh WHMIS training where hazard information changed — generic 2015-era WHMIS content does not cover the new classes.
5. HMIRA claimants: review pre-transition filings and be ready to refile on request.

How Certigo can help

Certigo's SDS Manager flags outdated sheets and keeps your library current, and our WHMIS training reflects the amended HPR. Explore the SDS Manager or view our WHMIS courses.

Sources

• SOR/2022-272 — Canada Gazette, Part II, January 4, 2023
• Health Canada — Amendments to the Hazardous Products Regulations
• Health Canada — WHMIS program newsletters (December 2025, March 2026)

This article is general information, not legal advice. Always verify requirements against the official texts before making compliance decisions.