What Changed for TDG Safety Marks?
On June 17, 2026, Transport Canada published SOR/2026-112 in the Canada Gazette, Part II, introducing numerous changes to the Transportation of Dangerous Goods Regulations (TDGR).
The amendment, formally titled Regulations Amending Certain Regulations Made Under the Transportation of Dangerous Goods Act, 1992 (Part 12 and International Harmonization Update), represents a significant harmonization update for Canadian dangerous goods requirements.
You can find the full Canada Gazette publication HERE.
This article focuses on some of the significant changes to Part 4 — Dangerous Goods Marks, particularly those affecting labels, placards, UN numbers and the lithium battery mark.
Hazard Wording Is Now Permitted on Labels
Words on Labels? Yes!
For the first time, Transport Canada is expressly allowing hazard wording to appear on most dangerous goods labels.
Section 4.7 has been amended to permit text describing the danger posed by the dangerous goods and illustrated by the label. This option does not apply to Class 7 labels or the Class 9 label specific to lithium batteries.
There are some important conditions. The text must be located below the symbol. For Class 1.4, 1.5 and 1.6 labels, it must appear below the class number shown in the upper corner. If the hazard wording is in a language other than English or French, an English or French translation must also be included. The additional wording cannot obscure the symbol or other required information on the label.
Customers are not required to replace existing compliant labels simply to add hazard wording. This is a new option, not a general requirement to add text to every label.
However, companies using labels produced for multiple jurisdictions should review their existing label inventories and specifications. Labels containing wording used under U.S. or international requirements may now have greater compatibility with the TDGR, provided all of the Canadian conditions are satisfied.
Before ordering or printing new labels, verify that the wording, location, dimensions and overall design comply with the amended Canadian requirements.
Hazard Wording Is Now Permitted on Placards
Placards Can Include Hazard Wording Too. Section 4.8 received a similar amendment.
Except for Class 7 placards, text describing the danger represented by the placard may now be included. The text must appear below the symbol or, for Class 1.4, 1.5 and 1.6, below the class number in the upper corner.
Again, wording in a language other than English or French must be accompanied by an English or French translation, and the wording cannot obscure required information.
This provides Canadian shippers with additional flexibility and brings the TDGR closer to dangerous goods marking practices used internationally.
Review placards currently used on vehicles and large means of containment, particularly placards sourced for cross-border operations. Do not assume that because a placard is acceptable under 49 CFR it automatically complies with the TDGR. Confirm that its dimensions, layout, wording and other required elements satisfy the amended Canadian requirements.
New UN Number Display Requirements
Section 4.12(3) has introduced the UN number height requirement for small means of containment. This now aligns with the international regulations.
Section 4.15.2 now provides clearer requirements for displaying UN numbers with placards.
Importantly, the UN number must be displayed without the prefix “UN” and in black characters at least 65 mm high.
It may be displayed:
- on an orange panel next to the applicable primary class placard; or
- within a white rectangle on the applicable placard, provided the rectangle does not obscure a symbol or text.
This is a good reason for customers to check existing placard and UN-number configurations. A display such as UN 1203, for example, should not be used where section 4.15.2 requires the four-digit number without the “UN” prefix.
Changes to IBC and Large Packaging Marks
Marking and Labelling an IBC? Section 4.15.3 has also been revised.
For an IBC or large packaging with a capacity of 3,000 L or less, the regulations permit either the applicable placard and UN number or, under the alternative provided by the section, the primary and subsidiary class labels together with the UN number and shipping name.
When using the label option, the shipping name and UN number must be displayed next to the label, although the UN number may instead appear without the “UN” prefix inside a white rectangle on the label if it does not obscure required information.
If the UN number is displayed next to the label, it must be in black characters at least 25 mm high.
Customers using IBCs should therefore review not only their labels but also the size, position and format of the UN number and shipping name.
The Lithium Battery Mark Is Changing
One change many shippers will welcome is the amendment to section 4.24 and the lithium battery mark.
Transport Canada has removed the requirement for the telephone number for additional information from the lithium battery mark, aligning Canada more closely with international requirements and the U.S. 49 CFR.
The dimensional requirements have also changed. The standard mark is now a square or rectangle at least 100 mm wide by 100 mm high, with hatching at least 5 mm wide. A reduced 100 mm by 70 mm version may be used when the shape or size of the means of containment prevents all required dangerous goods marks from being visible from the same viewpoint, provided the required elements are reduced proportionally.
Companies should update label artwork, printing systems, packaging instructions and purchasing specifications to the new lithium battery mark.
Don’t Overlook the 12-Month Transition Period
Existing stocks should not simply be discarded without checking the transitional provisions. SOR/2026-112 provides a 12-month transition period during which a person may continue complying with the TDGR as they read immediately before the amendment came into force.
Since SOR/2026-112 came into force upon publication on June 17, 2026, this effectively provides a transition through June 16, 2027, with the amended requirements applying thereafter.
This Canadian transition should be considered separately from transition dates under 49 CFR, ICAO, IATA, IMDG or other applicable modal regulations.
New Toxic-by-Inhalation Labels and Placards
The amendment also introduces Canadian recognition of dedicated toxic-by-inhalation marks:
Class 2.3 — Toxic-by-Inhalation Gases
Label and Placard
Class 6.1 — Toxic-by-Inhalation Substances
Label and Placard
These marks incorporate the words “INHALATION HAZARD.”
This is particularly useful for shipments moving between Canada and the United States because the amendment was intended to accept the U.S. 49 CFR toxic-by-inhalation label and placard as an alternative to Canada’s separate inhalation-hazard wording requirements.
When Is Separate Inhalation Hazard Wording Required?
There is an important operational point here.
For a small means of containment containing Class 2.3 or 6.1 dangerous goods that are toxic by inhalation, the words “inhalation hazard” or “dangereux par inhalation” must generally appear in characters at least 12 mm high next to the shipping name, unless the words are already part of the shipping name or already appear on one of the dangerous goods marks.
For a large means of containment, either of the applicable Class 2.3 or Class 6.1 placards may be used. If the dedicated toxic-by-inhalation placard is not used, the separate inhalation-hazard wording remains required, subject to the requirements in section 4.23.
So, while the new toxic-by-inhalation marks provide a convenient option, customers need to understand that choosing the standard Class 2.3 or 6.1 placard may leave an additional marking requirement.
New Optional Class 7 Placards
The amendment also introduces optional placard versions of the familiar Class 7 radioactive category labels:
- Category I — White
- Category II — Yellow
- Category III — Yellow
These are identified in the amended Part 4 appendix as “Label and Optional Placard.”
Organizations transporting Class 7 materials should review these new options carefully alongside the requirements of the TDGR and the applicable Canadian nuclear transportation regulations before changing their marking procedures.
What Should Dangerous Goods Shippers Do Now?
SOR/2026-112 is much larger than a simple label update. Companies transporting dangerous goods in Canada should use the transition period to review their entire dangerous goods marking program.
- Review label and placard inventories against the amended Part 4 specifications.
- Update lithium battery mark artwork to remove the telephone-number field and reflect the new dimensions.
- Check UN-number displays on large means of containment to ensure the “UN” prefix is not being used where section 4.15.2 requires the number without it.
- Review IBC marking procedures, particularly the 25 mm UN-number requirement when using the label option.
- Evaluate toxic-by-inhalation shipments to determine whether the new Class 2.3 or Class 6.1 marks simplify Canadian/U.S. cross-border compliance.
- Review Class 7 procedures before adopting the new optional placards.
- Update written procedures, training materials, artwork specifications and purchasing requirements so employees and suppliers are working from the amended TDGR.
- Coordinate with label and placard suppliers early. Waiting until the end of the transition period can create unnecessary problems with obsolete inventory or unavailable compliant stock.
Don’t Confuse Flexibility with Automatic Compliance
Remember that “optional” does not mean anything goes. Where the TDGR now permits an alternative label, placard or additional wording, all conditions associated with that option still have to be met.
Check the mode of transport and destination. A Canadian TDGR-compliant mark does not by itself guarantee compliance with 49 CFR, ICAO/IATA or the IMDG Code.
Preparing for the New TDG Requirements
The Part 4 amendments give dangerous goods shippers considerably more flexibility and improve alignment between Canada’s TDGR, the U.S. 49 CFR and international dangerous goods regulations. For many companies, that should eventually mean fewer Canada-specific labels and placards and easier management of cross-border shipments.
Don’t wait until the transition period ends. Now is the time to review your TDG labels, placards and marking procedures, identify what needs to change, and determine which new options could make your dangerous goods program simpler. Have questions about how SOR/2026-112 affects your shipments? Ask ICC’s Regulatory Experts today.
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