HazCom 2024 meets HPR: what North American SDS and labels must get right
North America is entering a new phase of chemical hazard communication which means that companies need to review their Safety Data Sheets (SDS) and labelling to ensure they are compliant.
With Canada completing its transition to the amended Hazardous Products Regulations (HPR) and the United States implementing HazCom 2024, companies face a dual‑market environment with new scientific criteria, updated hazard classes and revised SDS expectations. These shifts are not merely administrative, they fundamentally reshape how products must be classified, labelled and documented across the region.
These changes demand proactive portfolio‑wide SDS and label reviews for organisations placing products on the North American market. Failure to do so risks shipment delays, lost market access or regulatory penalties.
Compliance dates
Companies must update their SDS to meet the new requirements in the United States and Canada by the following deadlines:
SDS intended for the United States
- January 19, 2026 - SDS for substances must comply.
- July 19, 2027 - SDS for mixtures must comply.
SDS intended for Canada
- July 19, 2027 - All SDS intended for the Canadian market must comply.
Key regulatory changes
Both Canada and the United States have introduced several updated hazard classes to better align with the latest scientific understanding of chemical behaviour. These updates include:
Chemicals Under Pressure
A new hazard class that covers products containing gases dissolved, liquefied or compressed within a vessel. These products may not fit neatly into existing gas‑related categories, so this new class helps more accurately communicate the risks associated with high internal pressure and potential container rupture.
Non‑flammable aerosols (Category 3)
A new aerosol category that captures products which do not meet the criteria for flammability but may still present physical hazards such as pressure build‑up, container bursting, or other safety concerns during handling and storage.
This ensures that even low‑flammability aerosol products are properly identified and labelled for workplace safety.
Updated flammable gas classifications (1A/1B), including chemically unstable and pyrophoric gases
The flammable gases class has been expanded and refined into clearer subcategories to distinguish between gases with different levels of ignition risk. This includes specific identification of chemically unstable gases, which may react or decompose on their own, and pyrophoric gases, which can ignite spontaneously in air. These refinements help ensure that SDS and labels communicate not just that a gas is flammable, but how it behaves and what risks it poses during use, storage or transport.
These shared updates represent an effort by both countries to align with the Seventh Revised Edition of the Globally Harmonized System (GHS) with Canada additionally incorporating selected provisions from GHS Revision 8 and provide clearer, more granular hazard communication.
Can one SDS be used for Canada and USA?
Despite adopting the same updated hazard classes, the way Canada and the US implement these changes varies, creating important differences in classification and SDS obligations. These divergences include:
Area |
Canada |
United States |
| Desensitised explosives | Not adopted | Adopted under “Other Hazards” |
| Mandatory classification | Required for select substances | Not required |
| Combustible dust | Only if supplied in dust form | Required even if dust may form during processing |
| Ingredient disclosure | All hazardous ingredients above cut‑offs must be listed | Prescribed ranges required; narrowest range must be used |
These differences mean that a single SDS cannot simply be “tweaked” to work for both regions
Even though both countries have updated their frameworks in broadly similar ways, the underlying rules applied during classification, SDS authoring and hazard communication can lead to different outcomes for the same product in each jurisdiction.
SDS structure and content updates
Both Canada and the United States have introduced changes to how SDS must be structured and what information they must include. These changes go beyond simply updating hazard classifications. They affect the level of detail, the type of information required and how clearly hazards must be communicated.
1. More detailed toxicology information required (U.S., Section 11)
The U.S. now requires additional health information, including recognised carcinogen listings (NTP, IARC, OSHA), interactive health effects, and transparency when toxicology data is based on similar substances. This ensures downstream users have a clearer picture of potential health risks.
2. Updated physical property requirements (Canada & U.S.)
Both countries have refreshed the list of physical and chemical properties in Section 9. This means suppliers may need to update or re‑test values such as vapour pressure, flash point, density, and other factors, to meet the new format.
3. Possible changes to hazard statements (Canada & U.S.)
Because hazard classes such as aerosols and flammable gases have been updated, some products will require revised hazard statements and precautionary wording on both SDS and labels.
4. New downstream hazard disclosure (U.S., Section 2)
The U.S. now requires SDS to include hazards that may arise during typical use – for example, dusts created during processing or reactivity during mixing or heating. This expands hazard communication beyond the product “as supplied”.
How Ricardo can support you
North America’s regulatory landscape is evolving quickly, and the upcoming enforcement dates in 2026 and 2027 mean that companies must prepare now. The changes will reshape hazard classifications, SDS content and label requirements, impacting virtually every product in the market.
Ricardo is here to help you navigate these changes seamlessly, ensuring your documentation stays compliant, accurate and market ready.
SDS Authoring & Updating
- Full SDS creation for Canada (HPR) and the U.S. (HazCom 2024)
- Reclassification of products based on updated hazard criteria
- Incorporation of new ingredient disclosure rules, toxicological requirements, and physical property updates
- Ensuring updates within the required 90‑day window when new data becomes available
Label Authoring & Compliance
- Updated label elements reflecting new hazard classifications
- Region‑specific statements for U.S. vs. Canada
- Formatting compliant with local entity requirements and national regulations
Product Portfolio Impact Assessment
- Identification of which products require reclassification
- Gap analysis against new HPR and HazCom 2024 requirements
- Cross‑border harmonization recommendations
Strategic Consulting & Compliance Planning
- Support with transition planning
- Supply‑chain communication materials
- Regulatory guidance for commercial teams and customer‑facing roles
Contact our experts today to resolve any potential compliance issues with your SDS.
