As the December 15, 2025 WHMIS 2022 compliance milestone approaches, Health Canada has issued important clarifications that Canadian suppliers, importers, and manufacturers cannot afford to overlook. During a November 2025 Workplace Hazardous Products Program multistakeholder workshop, regulators addressed recurring questions around enforcement timelines, SDS accuracy, mixture classification, bilingual requirements, and audit expectations.
Taken together, the guidance sends a clear signal: while enforcement activities may be phased, responsibility for WHMIS 2022 compliance is immediate and ongoing. Organizations that delay updates to their Safety Data Sheets and labels risk falling out of alignment with the amended Hazardous Products Regulations.
What Is WHMIS 2022 and Why It Matters Now
WHMIS 2022 updates Canada’s hazard communication framework to align more closely with the Globally Harmonized System while introducing new expectations around classification rigor, documentation accuracy, and supplier accountability. These changes affect how hazardous products are classified, how SDSs are authored, and how information is communicated to downstream users.
For many organizations, WHMIS 2022 is not simply a regulatory update but a stress test for existing SDS processes. Legacy documents, manual classification methods, and fragmented workflows are increasingly difficult to defend under heightened regulatory scrutiny.
Health Canada’s WHMIS 2022 Enforcement Timeline Explained
One of the most closely watched aspects of WHMIS 2022 is enforcement. Health Canada confirmed that as of December 15, 2025, suppliers must ensure all hazardous products have hazard classifications, Safety Data Sheets, and labels that fully comply with the amended Hazardous Products Regulations.
While Health Canada has indicated it will focus on compliance promotion for mixtures until July 19, 2027 — aligning with the U.S. OSHA timeline — this does not represent a delay in compliance obligations. Audits may still occur at any time, and non-compliant SDSs or labels may trigger corrective actions.
In practical terms, organizations should not interpret phased enforcement as a grace period. Compliance responsibility exists regardless of enforcement focus, and regulators expect suppliers to demonstrate due diligence from day one.
WHMIS 2022 SDS Accuracy Requirements
At the core of WHMIS 2022 compliance is SDS accuracy. Health Canada was explicit that suppliers are ultimately responsible for the correctness of their Safety Data Sheets. This responsibility does not shift to regulators, customers, or third-party service providers.
During audits or compliance reviews, Health Canada may request full product formulations and independently assess hazard classifications. These evaluations apply a conservative, risk-based approach, particularly for mixtures. When ingredient concentrations vary, classifications must be based on the maximum possible concentration rather than an average or midpoint.
Health Canada also emphasized that inaccurate or misleading SDS content remains a persistent compliance risk. Common issues include conflicting signal words, improper or empty pictograms, visual elements that contradict precautionary statements, or marking information as “not applicable” when data is simply unavailable. Even minor inconsistencies can undermine the credibility of an SDS and draw regulatory attention.
WHMIS 2022 Labeling and Content Requirements
WHMIS 2022 labeling requirements reinforce the need for internal consistency and clarity. Labels must accurately reflect hazard classifications and align fully with SDS content. Mismatches between labels and SDSs are viewed as red flags during inspections.
Health Canada highlighted that pictograms, signal words, and hazard statements must be complete and appropriate for the classified hazards. Decorative or contradictory imagery, incomplete pictograms, or ambiguous precautionary language may be considered misleading and non-compliant.
Bilingual SDS Requirements Under WHMIS 2022
Language requirements were another key area of clarification. Under WHMIS, Canadian SDSs must be provided in both English and French at the time of sale. Supplying an English-only SDS with the intention to translate it later does not meet regulatory requirements.
For organizations managing large product portfolios or operating across multiple jurisdictions, bilingual SDS delivery introduces significant operational complexity. Without centralized workflows and version control, maintaining synchronized English and French SDSs can quickly become unmanageable and increase compliance risk.
Supplier Identification and Emergency Contact Requirements
Health Canada also reiterated expectations related to supplier identification and emergency contact information. SDSs and labels must list a Canadian manufacturer or importer, and foreign or non-resident importer addresses generally do not satisfy Hazardous Products Regulations requirements.
Emergency phone numbers must also meet specific criteria. CANUTEC numbers are not permitted on SDSs or labels, while services such as CHEMTREC may be acceptable if they meet regulatory standards. Incorrect or non-compliant emergency contact information remains a common audit finding.
Why Manual SDS Processes Fall Short Under WHMIS 2022
These clarifications underscore a broader reality for EHS and regulatory teams. Manual, document-based SDS processes are increasingly difficult to defend in an environment defined by frequent formulation changes, evolving regulatory interpretations, bilingual obligations, and heightened audit expectations.
As WHMIS 2022 raises the bar for accuracy and accountability, organizations relying on spreadsheets, static documents, or disconnected translation workflows face growing compliance and operational risks.
How TotalSDS Supports WHMIS 2022 Compliance
TotalSDS by Enhesa helps organizations address these challenges with a structured, scalable approach to SDS compliance with dependable SDS software. SDS Author applies rules-based logic to hazard classification and SDS authoring, helping ensure classifications are applied consistently and conservatively in line with WHMIS and GHS requirements. By embedding regulatory rules directly into the authoring process, organizations reduce reliance on manual judgment and lower the risk of misclassification.
SDS Manager complements authoring by providing a centralized, always-available repository for Safety Data Sheets. With version control, audit trails, and controlled distribution, organizations can demonstrate due diligence during inspections and ensure workers always have access to the most current, compliant SDSs. This capability is particularly valuable for organizations operating across multiple sites or jurisdictions.
For organizations dealing with legacy SDS issues, frequent formulation changes, or limited internal resources, SDS Professional Services offers expert-led remediation and validation support. Backed by Enhesa’s global regulatory expertise, these services help identify compliance gaps, correct non-conforming SDSs, and align documentation with evolving WHMIS 2022 expectations.
Preparing for WHMIS 2022 Audits and Ongoing Compliance
Health Canada’s latest guidance reinforces a critical message: WHMIS 2022 compliance is not a one-time project or a future concern. It is an ongoing operational responsibility that demands accuracy, consistency, and audit readiness.
Organizations that invest now in conservative hazard classification, bilingual SDS workflows, and scalable SDS management systems will be better positioned to withstand inspections, reduce regulatory risk, and protect worker safety. TotalSDS by Enhesa helps organizations move beyond reactive compliance toward a proactive, defensible SDS strategy—turning regulatory complexity into confidence.
