WHMIS Canada: What to Do Before December Compliance Deadline

In 2022, Canada amended Workplace Hazardous Materials Information System (WHMIS) regulations to align more closely with the United Nations’ Globally Harmonized System (GHS) for classifying and labelling chemicals. 

We are now approaching the end of the three-year implementation period that was set when the regulations first came into effect. By December 15, 2025, all suppliers must ensure that product classifications, labels and Safety Data Sheets (SDS) comply with the amended Hazardous Products Regulations (HPR). Employers and workers should review and update their WHMIS training before this date to stay compliant and maintain a safe workplace.

WHMIS definition

WHMIS stands for Workplace Hazardous Materials Information System and is Canada’s national hazard communication standard. It ensures workers have accurate and consistent information about hazardous products used in their workplaces, including labelling requirements and Safety Data Sheets (SDS).

WHMIS Canada aligns with the Globally Harmonized System (GHS) of classification and labelling of chemicals, making it easier for international suppliers and employers to follow consistent safety standards.

Aligning WHMIS Canada with the Globally Harmonized System (GHS)

The GHS is a United Nations initiative that standardizes how chemical hazards are classified and communicated worldwide. Aligning WHMIS with GHS provides clear benefits for Canadian workplaces, including:

• Consistent hazard communication across borders
• Expanded hazard classes and clearer definitions
• Standardized SDS format and terminology
• Better alignment with Transport of Dangerous Goods (TDG) regulations

The most recent updates to WHMIS in Canada are designed to simplify compliance for multinational suppliers while improving worker protection through the provision of clearer information.

What’s changing under WHMIS 2025?

Recent amendments to the Hazardous Products Regulations (HPR) introduce several updates that suppliers and employers must follow before December 15, 2025.

Key changes include:

• New hazard classes and subcategories - e.g. “chemicals under pressure” and updated flammable gas definitions
• Enhanced SDS requirements - Sections 9 and 14 now include more detailed physical and chemical property descriptions
• Full disclosure of hazardous ingredients - all ingredients above cutoff levels must now be listed, even if not contributing directly to classification
• Improved label and SDS consistency - by the deadline, all labels and SDS must follow the new format and content standards

These changes aim to create greater transparency, accuracy and consistency across all hazardous products sold or used in Canada.

Who must comply with WHMIS in Canada?

Suppliers

The upcoming deadline primarily affects suppliers of hazardous products, which includes:

• Manufacturers - those who produce and sell hazardous products in Canada
• Importers - those who bring hazardous products into Canada for sale or internal use
• Distributors - those who resell hazardous products without modification

However, employers and workers must also understand the changes. Employers are responsible for ensuring workplace labels and SDS match the latest standards, in addition to facilitating staff training accordingly.

Employers and Workers

The changes also have major implications for employers and workers.

Employers are legally responsible for ensuring that all workplace labels and Safety Data Sheets (SDS) reflect the latest standards. They must also update WHMIS training so that staff understand new hazard classifications and labelling requirements. Keeping training current isn’t just about compliance - it’s essential for maintaining a safe workplace.

WHMIS transition period and compliance deadline

The latest WHMIS amendments took effect December 15, 2022, with a three-year transition period ending at midnight on December 14, 2025.

During this transition:

• Suppliers may comply with either the previous or updated HPR, but not both
• All SDS and labels must be consistent with one version of the regulation

From December 15, 2025, only the updated WHMIS 2025 standard will be accepted. Non-compliance risks include:

Legal & financial penalties

Under the Hazardous Products Act, non-compliance with any provision (or regulations / orders made under it) is an offence.

• On indictment (i.e. more serious prosecution): up to CAD 5,000,000 in fines or imprisonment up to two years, or both
• On summary conviction (less serious route):
  – First offence: up to CAD 250,000 fine, or imprisonment up to six months, or both
  – Subsequent offences: up to CAD 500,000 or imprisonment up to 18 months, or both
• If someone knowingly or recklessly contravenes provisions, harsher punishments may apply (e.g. higher fines, longer imprisonment)
• For companies (i.e. non-individuals), officers, directors or agents who authorize or acquiesce to the offence may also be held personally liable

Other enforcement measures

Fines are not the only penalty for non-compliance. Health Canada and provincial/territorial occupational health & safety (OHS) authorities can use other enforcement actions. Some of these include:

• Orders to take corrective measures (e.g. to reclassify, re-label, update SDS, stop distribution)
• Product recalls or removals from the marketplace (if the product is non-compliant or poses hazard)
• Refusal of importation - non-compliant products can be denied entry at the border or seized
• Seizure or forfeiture of the non-compliant product or goods
• Inspections, audits and ongoing compliance monitoring - regulatory authorities can demand documentation, inspect SDS and labels, require training records, etc.
• Reputation, liability and civil claims - even beyond regulatory penalties, a company may face lawsuits, reputational damage, insurance claims, and consumer or downstream liability if improper hazard communication leads to injury, damage or environmental harm

What should suppliers, employers and workers do before December 15?

Suppliers:

1. Review and reclassify products under the new hazard definitions
2. Update all SDS and labels to match WHMIS 2025 requirements
3. Retain qualified SDS authors, if necessary
4. Prepare for potential inspections or enforcement actions post-deadline

Employers:

1. Verify which version of WHMIS suppliers are using
2. Replace old SDS and labels with updated versions
3. Facilitate training for staff on new hazard classes, pictograms and SDS format
4. Keep an accurate inventory of hazardous products
5. Keep record of staff training including details of content covered, staff involved and the date of completion

Workers:

1. Take part in WHMIS refresher training
2. Learn how to interpret the new label symbols and SDS elements
3. Stay alert for product updates in your workplace

The importance of WHMIS training and education

Even though suppliers bear most regulatory obligations, employers and workers are the ones directly exposed to hazardous products. With new hazard classes, redefined categories and more detailed SDS requirements, up-to-date WHMIS education is essential for workplace safety and compliance.

Enroll in a WHMIS course through the Canadian Institute for Food Safety (CIFS) to ensure your training aligns with the latest WHMIS 2025 requirements. The course covers everything you need to interpret the new system with confidence - from understanding revised labels and pictograms to responding safely to hazardous products in the workplace.

Frequently Asked Questions

Q. What does WHMIS stand for?

A. WHMIS stands for Workplace Hazardous Materials Information System, which is Canada’s national hazard communication standard.

Q. When is the WHMIS 2025 compliance deadline?

A. Suppliers must comply with the new WHMIS regulations by December 15, 2025.

Q. Who enforces WHMIS in Canada?

A. Health Canada regulates WHMIS under the Hazardous Products Act, while provincial and territorial workplace safety agencies enforce it within workplaces.

Q. Do employers also need to comply with WHMIS regulations?

A. Yes. Employers must ensure their workplace SDS, labels and training align with the updated WHMIS requirements.

Q. What happens if a supplier fails to comply with WHMIS regulations?

A. Non-compliance may result in penalties, fines up to $5 million or imprisonment, depending on the violation.

Q. Can you enroll multiple staff members in the WHMIS course at the same time?

A. Yes. CFS offers business accounts that help to make training streamlined, including enrolment services, certificate collation and more.