- SDSs no longer expire after three years in Canada; that rule ended with WHMIS 1988.
- Canada: update within 90 days of becoming aware of significant new data (180 days for labels).
- United States: add significant new information to the SDS within three months.
- EU and GB: update without delay and send the new version to everyone you supplied in the last 12 months.
A question that comes up often: "Our SDS is from 2019. Is it still valid?" The short answer: an SDS does not expire on a set date in any of the four major markets. What triggers an update is new information, and each market gives you a deadline to act on it.
Canada (WHMIS 2015)
Under WHMIS 1988, suppliers had to refresh every material safety data sheet every three years. That rule is gone. The Hazardous Products Act and Regulations no longer require a three-year update.
Instead, the Hazardous Products Regulations use the idea of significant new data: new information that changes the product's classification, or changes how people should protect themselves from the hazard. When a supplier becomes aware of it:
- The SDS must be updated within 90 days.
- The label must be updated within 180 days.
- Until then, the supplier must give buyers a separate written notice of the new data and the date it became known.
Employers have a duty too: every hazardous product must have an up-to-date SDS when it enters the workplace, and an employer who becomes aware of significant new information must add it to the SDS they keep.
United States (OSHA HazCom)
OSHA's Hazard Communication Standard (29 CFR 1910.1200) has no expiry date either. If the manufacturer, importer or employer preparing the SDS becomes newly aware of significant information about the hazards of a chemical, or about ways to protect against them, that information must be added to the SDS within three months.
Separately, the 2024 update to the standard means many SDSs need a one-time revision anyway. See our article on the 2024 HazCom update and its new deadlines.
European Union and Great Britain (REACH)
Article 31(9) of REACH, which also applies in Great Britain under UK REACH, requires the supplier to update the SDS without delay when:
- new information becomes available that may affect risk management measures, or new information on hazards;
- an authorisation has been granted or refused; or
- a restriction has been imposed.
The new, dated version must be sent free of charge to every recipient who received the product in the previous 12 months, with the changes identified, usually in section 16.
Triggers that are easy to miss
- Harmonised classification changes in the EU (the ATPs to CLP), such as the 23rd ATP, which becomes mandatory on 1 February 2027.
- New hazard classes, such as the EU's endocrine disruptor and PBT/PMT classes. See our article on the 1 November 2026 deadline.
- Supplier changes: a new raw-material supplier often means a new composition and new data.
- Exposure limits that change for an ingredient, which affect section 8.
A practical rule of thumb
Even without a legal expiry date, review every SDS at least every few years, and whenever a formulation, supplier or regulation changes. An SDS that is several years old is not automatically non-compliant, but it is the first place an inspector or customer will look.
Sources
General information, not legal advice. Checked against the official sources above on 7 October 2026. Rules change: for your own products, ask for a spot-check.
