- Anyone who imports a hazardous product in the course of business is a supplier under the Hazardous Products Act.
- You must obtain or prepare a compliant SDS on or before importation, and the product must carry a compliant label, unless it is imported to be labelled before use or sale.
- The Canadian importer normally appears as the supplier. Importing for your own workplace lets you keep the foreign supplier's details.
- Keep copies of labels and SDSs and records of purchases and sales for six years.
If your company buys chemical products from a foreign supplier, you are not just a customer under Canadian law. For products intended for use in Canadian workplaces, the importer takes on the supplier's obligations, including the safety data sheet and the label.
Before you order
- Ask for the full composition with CAS numbersNeeded to classify under WHMIS
- Ask for test data such as flash point and pH
- Get the foreign SDS in its latest version
Canadian documents
- SDS in English and FrenchIn place on or before importation
- Canadian supplier detailsOr the foreign supplier if for your own use
- Classification checked against WHMIS
Labels
- Bilingual supplier labelOn the product or container
- Or label before use or saleWith evidence for an inspector
- Label matches section 2 of the SDS
Records
- Copies of every label and SDSKept 6 years
- Who you bought from, quantities and dates
- Sales records
Are you a supplier?
The Hazardous Products Act defines a supplier as a person who, in the course of business, sells or imports a hazardous product. The supplier rules apply to hazardous products intended for use, handling or storage in a workplace in Canada. Consumer chemical products sold to the public fall under consumer product rules instead, and many ranges need both.
What must be in place
Section 14 of the Act prohibits importing a hazardous product intended for workplace use unless:
- the importer obtains or prepares an SDS that meets the Hazardous Products Regulations on or before importation, and
- the product or its container has a label that meets the regulations.
There is one useful exemption for the label: a product may be imported in order to be brought into compliance with the labelling rules before it is used or sold. If an inspector asks, you must show credible evidence that this is happening (HPR section 5.15). The SDS still has to be in place on or before importation. Labels and SDSs must not contain false or misleading information.
Why the foreign supplier's SDS rarely works as it is
- Language: the SDS and label must be in English and French. See bilingual SDSs in Canada.
- Supplier details: a Canadian manufacturer or importer must normally be named, with a name, address and telephone number.
- Classification: WHMIS adopted slightly different parts of the GHS than the US or the EU, so the classification, pictograms or statements may differ.
- Ingredient disclosure: since the HPR amendments, section 3 must list every ingredient classified in a health hazard class above its concentration cut-off. Concentrations withheld as confidential must use the prescribed ranges.
A US SDS is the closest starting point, but it is still not compliant as it stands: see can you use a US SDS in Canada?
Importing for use in your own workplace
If you import a product only for use in your own workplace and do not resell it, you may keep the foreign supplier's name, address and telephone number on the SDS and the label instead of your own (HPR section 5.9). The rest of the supplier requirements still apply, including English and French. As an employer, you also keep your workplace duties: worker training, workplace labels where needed, and SDSs readily available to workers.
Records to keep
Suppliers who sell or import hazardous products must keep, for six years after the end of the year they relate to:
- a copy of each label and SDS,
- records of products obtained from another person: their name and address, the quantity and the month and year obtained, and
- sales records.
The records must be kept at your place of business in Canada and given to Health Canada on written request.
Who checks
Health Canada is responsible for the supplier rules, including importers. It has said it will focus on compliance promotion until 19 July 2027 before returning to its standard risk-based enforcement. Provincial and territorial inspectors enforce the workplace rules at your customers' sites, and they often find supplier problems first.
Sources
General information, not legal advice. Checked against the official sources above on 10 October 2026. Rules change: for your own products, ask for a spot-check.
