Health Canada Aligns GHS Enforcement with OSHA Deadline

Health Canada Aligns GHS Enforcement with the OSHA Deadline

The December 15, 2025, compliance deadline for the amended Hazardous Products Regulations (HPR) in Canada has been a major focus for businesses. This date marks the end of the three-year transition period, after which all non-registered industrial hazardous products sold in Canada must have compliant GHS Safety Data Sheets (SDSs), and labels.

However, a critical challenge emerged for many Canadian companies that often create unified U.S./Canadian SDSs to meet both OSHA’s Hazard Communication Standard (HCS) and the Workplace Hazardous Materials Information System (WHMIS) requirements. The issue? The U.S. timeline is different.

The Challenge of Two Timelines

The U.S. Occupational Safety and Health Administration (OSHA) recently finalized an update to the HCS, primarily aligning with the seventh revision of the United Nations’ Globally Harmonized System (GHS) of Classification and Labelling of Chemicals (with some elements from GHS Revision 8). This U.S. final rule was published on May 20, 2024, and establishes a compliance deadline of July 2027. To understand the impending OSHA deadlines, check out our related post.

This significant gap—Canada’s deadline in December 2025 versus the U.S. deadline in July 2027—created a major headache for industry, leading to concerns about regulatory discrepancies, particularly for updating SDSs and labels for mixtures. Stakeholders rightly argued for greater alignment between the two trusted foreign regulators to maintain efficiency and reduce trade barriers.

Health Canada recognized the importance of regulatory consistency for Canadian companies and the efficiencies gained through harmonized requirements with the US. Health Canada has reaffirmed its commitment to the objectives of the Canada-U.S. Regulatory Cooperation Council, including the mutual alignment of GHS implementation.

To address industry concerns and support both robust economic growth and trade, Health Canada has announced a pragmatic, risk-based approach to compliance and enforcement:

Until July 19, 2027, (the U.S. implementation deadline for mixtures), Health Canada will focus on compliance promotion with regulated parties
From July 19, 2027, onwards, compliance and enforcement will follow a risk-based approach as per standard Departmental and program guidance

This response is a direct effort by Health Canada to reduce “regulatory red tape,” a commitment highlighted in the recent Report on Red Tape Reduction. By temporarily adjusting the enforcement focus, Canadian companies gain the necessary time to update their materials in parallel with their U.S. counterparts, ensuring seamless compliance across the border.

What’s Next for Industry?

While Health Canada is providing flexibility, the expectation remains that companies will transition to full compliance with the amended HPR. This ongoing alignment process will likely be a key topic of discussion at the upcoming Fall 2025 multi-stakeholder workshop.

Event Details:

What: WHPP multistakeholder workshop
When: Thursday, November 20, 2025, from 12:30pm (Virtual)
Register: Interested parties should register by November 12.

This extension of the enforcement timeline provides a critical window for companies to strategize their updates and coordinate their compliance efforts between both jurisdictions. Don’t mistake the adjusted enforcement focus for an abandonment of the regulatory change; it’s an opportunity to prepare thoroughly and efficiently.

ICC Compliance Center has a team of full-time Regulatory Experts who have years of experience and are certified/recognized in their field of expertise. Contact us about authoring, reformatting, updating, and translating your SDSs. Ask us your tough questions by calling 855.734.5469 or send us an email, we’re happy to help.