OSHA HazCom vs WHMIS vs EU CLP: SDS Requirements by Jurisdiction

Imperium SDS guides · 2026-08-23

The Globally Harmonized System (GHS) gave the world a common vocabulary for chemical hazards — the same pictograms, signal words, and H-statements appear on safety data sheets from Houston to Hamburg. But GHS is a model regulation published by the UNECE, not a law. Each jurisdiction adopts it through its own legislation, at its own revision level, with its own additions. The result: an SDS written for the United States is rarely compliant as-is in Canada, the EU, or Mexico. This guide walks through what actually changes.

The four regimes at a glance

Section 1: who stands behind the sheet

The supplier-identification block is the most commonly missed jurisdictional detail, because it looks like boilerplate.

• United States. The name, address, and telephone number of the manufacturer, importer, or other responsible party, plus an emergency phone number.
• Canada. WHMIS 2015 requires an initial supplier identifier — the name, address, and telephone number of the Canadian manufacturer or importer. A US supplier's address alone generally does not satisfy this; there are limited situations where an importer may retain the foreign supplier's information, so verify current requirements with Health Canada for your specific supply arrangement.
• European Union. REACH Annex II expects the details of the supplier established in the EU/EEA who is placing the substance or mixture on the market — a non-EU manufacturer typically appears through its EU importer or only-representative — and an email address of a competent person responsible for the SDS. Hazardous mixtures sold to consumers or professional users also trigger poison-centre notification and a UFI code under CLP Annex VIII.
• Mexico. Supplier identification in Spanish, with an emergency contact reachable from Mexico.

Classification: self-declared vs harmonised

Under OSHA HazCom, WHMIS 2015, and NOM-018, the supplier classifies the product itself by applying GHS criteria to the available data. Two suppliers can legitimately reach different classifications for the same substance if they weigh the evidence differently.

The EU is different in an important way. CLP Annex VI contains thousands of harmonised classifications — legally binding minimum classifications agreed at the EU level. If your ingredient is listed, you must apply at least that classification; you cannot self-classify it more leniently. Annex VI also assigns specific concentration limits (SCLs) and M-factors to many substances, which override the generic concentration cut-offs used in mixture classification. A mixture that is unclassified under OSHA's generic thresholds can be classified in the EU because an ingredient carries an SCL — and vice versa. (Our GHS classification guide covers how these thresholds work.)

Canada layers a few classes onto GHS that the US did not adopt in the same way, and each jurisdiction has adopted different GHS revision levels at different times — another reason a literal copy-paste between regions fails.

Section 8: whose exposure limits?

Occupational exposure limits are national (or sub-national) law, so Section 8 changes with every border crossing:

• US: OSHA PELs are the enforceable values; ACGIH TLVs and NIOSH RELs are customarily listed alongside them.
• Canada: OELs are set provincially — Ontario, Alberta, British Columbia, and Quebec each publish their own tables, many based on ACGIH TLVs but not identical.
• EU: the EU publishes indicative occupational exposure limit values (IOELVs), which member states transpose into national limits — Germany's AGWs and France's VLEPs, for example, derive from but do not always match the EU values. An EU SDS should reflect the national limits of the destination market where practical.
• Mexico: national exposure limits are published separately from NOM-018 (in the STPS workplace-environment standard); verify current requirements for the substances involved.

This is a large enough topic that we cover it separately in SDS Section 8 exposure limits: PELs, RELs, TLVs, and IOELVs.

Section 15: the regulatory-inventory section

Section 15 is jurisdiction-specific by definition. A US sheet cites TSCA inventory status, SARA 302/313, CERCLA reportable quantities, and state lists such as California Proposition 65. A Canadian sheet addresses DSL/NDSL status. An EU sheet covers REACH matters — SVHC Candidate List presence, authorisations, and restrictions — drawing on ECHA's Candidate List. A Mexican sheet references the applicable NOMs. Because these lists change on their own schedules, Section 15 is also a leading reason sheets go stale — see when an SDS must be updated.

Language requirements

• Canada requires SDSs and labels in both English and French — either one bilingual document or two unilingual ones.
• EU member states may require (and nearly all do) the SDS in an official language of the state where the product is placed on the market. Selling into five countries can mean five language versions of the same sheet.
• Mexico requires Spanish.
• US requires English; other languages may be provided in addition.

Because the SDS has essentially no free-form prose — hazard statements, precautionary statements, and section titles are all fixed regulatory text with official translations — translation is one of the more mechanical parts of multi-jurisdiction authoring, provided the official statement wording is used rather than a fresh machine translation.

What stays the same

The good news: the skeleton is shared. All four regimes use the 16-section SDS format, the nine GHS pictograms, the two signal words, and the H/P statement system. A well-structured master document — one classification engine, one composition, one set of physical data — can be rendered per-jurisdiction by swapping the supplier block, the exposure-limit tables, the Section 15 inventory screens, applicable classification differences (Annex VI/SCLs in the EU), and the language. That is exactly how multi-market SDS authoring should be organized, whether you do it with software or with a very disciplined set of templates. For the section-by-section mechanics, start with how to write a GHS-compliant SDS.

This guide is general educational information, not legal or regulatory advice. Requirements vary by jurisdiction and change over time — always have safety data sheets reviewed by a qualified person before use. See our Terms of Service.

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