Written on: September 1, 2025 by Cassandra Taylor
The Dec.15, 2025, deadline marking the end of the updated Workplace Hazardous Materials Information System (WHMIS 2022) transition period is fast approaching. If you have not already updated your documentation, now is the time to act.
Here at SPRAY, we’ve been tracking the Government of Canada’s amendments to the Hazardous Products Regulations (HPR) and Schedule 2 of the Hazardous Products Act (HPA)—particularly as they relate to aerosol products—since my March 2021 column on the proposed changes. In March 2023, we discussed the implementation of these changes. With the deadline just around the corner, I’m back with one final column to help ensure you are on track. If you sell hazardous products used by workers in Canada, your safety data sheets (SDSs) and labels must comply with the new requirements by the December deadline to avoid disruptions.
New supplier guidance & cross-border variances
Since our last discussion, Health Canada has released a new guidance on the WHMIS supplier requirements, intended for suppliers of hazardous products destined for Canadian workplaces. This manual replaces the earlier WHMIS 2015 Technical Guidance and was most recently updated in June 2025 to include comparisons between the requirements of the HPR and the U.S.’ Hazard Communication Standard (HCS).
Health Canada refers to these differences as “variances” that may arise from the need to maintain Canada’s existing level of worker protection or from differences in legislative frameworks between the two countries. These variances are integrated throughout the new guidance, appearing alongside the relevant regulatory provisions. Examples include the requirement for bilingual SDSs and labels; the mandatory inclusion of a Canadian supplier identifier on both the SDS and label; and specific cases where label elements may differ from those required under the U.S. system. Further amendments to the guidance are expected as Health Canada continues to identify and clarify emerging issues during the transition to WHMIS 2022.
Aerosol classifications under WHMIS 2022
As a reminder, under WHMIS 2022, aerosol products are no longer classified as “Gases Under Pressure.” The former “Flammable Aerosol” hazard category has been replaced with the broader “Aerosol” classification, now comprised of three categories:
• Category 1 and Category 2 for flammable aerosols
• Category 3—newly introduced for non-flammable aerosol products
Label elements for aerosols have also been updated to align with Annex 3 of the Globally Harmonized System of Classification & Labeling of Chemicals (GHS) 7th Revised Edition. One of the most notable changes across all three aerosol categories is the optional removal of the compressed gas pictogram, which was previously required. Aerosol Categories 1 and 2 will continue to require the flammable pictogram, while Category 3 does not require a pictogram for flammability.
Label comparison for non-flammable aerosols
The chart on the previous page provides a side-by-side comparison of label elements for the non-flammable (Category 3) aerosol classification under the previous WHMIS 2015 and the updated WHMIS 2022 legislation. While no pictogram is needed for non-flammable aerosols, the Hazard Statement has changed, and there are additional Precautionary Statements to consider that did not apply to the previous “Gas Under Pressure” category.
Keep in mind that other label elements may be required if the product presents other health or physical hazards. Be sure to conduct a comprehensive hazard assessment to confirm all applicable labeling requirements.
Aerosols vs. Chemicals under pressure:
Watch the Packaging
It’s important to keep in mind the difference between aerosol products and the newly adopted “Chemicals Under Pressure” classifications, which were taken from the GHS 8th Revised Edition. Chemicals Under Pressure are:
• Liquids or solids pressurized with a gas at ≥ 200 kPa at 20°C (68°F);
• Packaged in a container other than an aerosol dispenser; and
• Classified into Categories 1, 2 or 3 based on flammable content and heat of combustion.
Chemicals Under Pressure are excluded from the Flammable Gases, Gases Under Pressure, Flammable Liquids and Flammable Solids hazard classes and they are not classified as “Aerosols,” even if they share similar characteristics. A change in packaging design can directly impact classification. For example, removing the aerosol valve from a pressurized container may be sufficient to shift the product’s classification from an “Aerosol” to a “Chemical Under Pressure” under WHMIS 2022.
This distinction between “Aerosol” and “Chemical Under Pressure” becomes particularly important in borderline cases. For example, spray foams or semi-solid formulations that are pressurized but use a non-standard actuator or require manual release may fall outside of the aerosol definition, depending on how they function. Non-spray pressurized containers, such as pump-assisted tanks used in industrial applications, may be classified as Chemicals Under Pressure if they meet the pressure and content criteria but do not function as aerosol dispensers.
Functionality and packaging design, not just pressure or contents, determine classification. It’s essential for suppliers to carefully assess any changes in container format, especially during reformulations or packaging redesigns, to maintain the correct classification under WHMIS 2022.
Why WHMIS 2022 compliance matters
Health Canada manages the risks hazardous products pose to worker health and safety through a range of compliance and enforcement activities. These are grouped into three main categories:
1. Compliance promotion
2. Compliance monitoring
3. Enforcement actions
In more serious cases, Health Canada may escalate to enforcement measures to address non-compliance or mitigate potential risks. These actions may include issuing warning letters; seizing, detaining, or disposing of non-compliant products; or ordering a stop to the sale or importation of the hazardous product.
Failure to comply with WHMIS 2022 requirements can result in significant legal and financial consequences, including fines, legal prosecution, reputational harm and, in the most serious instances, imprisonment. Beyond regulatory penalties, non-compliance can have severe health and safety impacts, including workplace injuries or fatalities due to inadequate hazard communication and improper handling procedures.
At Nexreg, we are actively supporting clients through their transition to WHMIS 2022. In our experience, many companies have yet to update their SDSs and labels to ensure full compliance. Delays are especially common for distributors and private label suppliers who are dependent on upstream manufacturers for updated product information. That is why we strongly recommend taking a proactive approach. Don’t wait until the last minute to begin gathering the necessary data. If your WHMIS 2022 updates are not already underway, now is the time to review your product inventory and determine what changes are required to meet the new regulatory standards before the December 2025 deadline. SPRAY
