1

Joint OSHA/Health Canada Comparison of

Labelling Requirements for Hazardous Products

Label comparison for shipped containers

Requirement

United States Hazard 

Communication Standard

(HCS) 2012

Canadian Hazardous 

Products Regulations

(HPR)

Product identifier Required, and must be identical to the product identifier on the safety 

data sheet.

Signal word Required. If both “danger” and “warning” are attributed to the product’s 

classification, only “danger” may appear. Repetition of the signal word is 

not permitted.

Pictogram All pictograms attributed to the 

product’s classification must 

appear together, with some 

exceptions as outlined in C.2.1. 

Pictograms must have a white 

background with a red border on 

shipped containers.

All pictograms attributed to the 

product’s classification must appear 

as set out in Schedule 3 of the HPR, 

with some exceptions outlined in 

subsection 3.6(3). 

Pictograms must have a white 

background with a red border, 

with the exception of the pictogram 

for Biohazardous Infectious 

Materials (BIM).

The HPR has a required pictogram 

for BIM that is unique to Canada.

The use of the environmental hazard pictogram from the GHS is not 

prohibited.

Pictogram red borders without symbols are not permitted; however, a 

completely blacked out pictogram is allowed provided that the red border 

is entirely obscured.

Repetition of a pictogram is not permitted. 

Hazard Statement All hazard statements that attribute to the product’s classification must 

be included.1

 

1 With some exceptions in Canada.
2

Label comparison for shipped containers

Requirement

United States Hazard 

Communication Standard

(HCS) 2012

Canadian Hazardous 

Products Regulations

(HPR)

Hazard Statement (con’t) The hazard statements must be 

from the HCS, which is based on 

GHS Rev. 3 with the addition of 

simple asphyxiants, combustible 

dusts, and pyrophoric gases. 

Hazard statements from GHS 

Rev. 4 or later may be listed if 

appropriate as long as the 

statements do not cast doubt 

or contradict the required HCS 

information.

“HNOC” is not required to be 

listed, but may be included as 

supplemental information.

The manufacturer/importer may 

omit information where it 

demonstrates it is inappropriate 

for the product. 

The wording of the hazard 

statement must be exactly the 

same as the wording in GHS Rev. 5 

or Schedule 5 of the HPR for simple 

asphyxiants, combustible dusts, and 

pyrophoric gases.

The Physical Hazards Not Otherwise 

Classified (PHNOC), Health Hazards 

Not Otherwise Classified (HHNOC) 

and BIM hazard classes do not have 

prescribed hazard statements, but 

appropriate statements must be 

provided by the supplier.

Omission of hazard statements 

attributed to the product’s 

classification is not permitted 

unless an exemption applies.

Hazard statements can be combined if the combination conveys the 

same information as would have been conveyed by each of the individual 

statements.

Precautionary Statements Appropriate precautionary statements must be included that attribute to 

the product’s classification.2

The precautionary statement(s) prescribed by the adopted GHS revision 

must be provided. However, minor variations in the wording of 

precautionary statement(s) that do not affect the intended meaning of the 

statement(s) are acceptable. 

Precautionary statements from 

Rev. 4 or later is permitted, as long 

as the statements do not cast 

doubt or contradict the required 

HCS information.

The non-GHS hazard classes do not 

have prescribed precautionary 

statements, but appropriate 

statements must be provided by 

the supplier.

 

2 With some exceptions in Canada.
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Label comparison for shipped containers

Requirement

United States Hazard 

Communication Standard

(HCS) 2012

Canadian Hazardous 

Products Regulations

(HPR)

Precautionary statements

(con’t)

Supplemental precautionary 

statements are permitted as long 

as the statements do not cast 

doubt on or contradict the 

required HCS information.

Where a product has multiple 

hazards and the precautionary 

statements are similar, the 

most stringent must be listed on 

the label. 

Additional precautionary 

statements are permitted as long 

as the information is not false or 

misleading.

Precautionary statements can be combined or omitted under specific 

conditions.

Name, address, phone

number, and responsible party 

[supplier identification]

The name, U.S. address, and U.S. 

phone number of the 

manufacturer, importer, or 

distributor or other responsible 

party must be on the label.

The information for the 

manufacturer, importer, or 

distributor or other responsible 

party on the label must be 

identical to that on the safety 

data sheet.

Foreign supplier information is 

permitted as long the U.S.

manufacturer, importer, or 

distributor or other responsible 

party’s address and phone number 

is also listed. 

The name, address, and phone 

number of the initial Canadian 

supplier (manufacturer or importer) 

must be provided. 

The distributor’s name, address,

and phone number can replace the 

initial supplier identifier.

Supplier identifying information on 

the label must be identical to the 

identifier on the safety data sheet.

Foreign supplier identifying 

information is additionally 

permitted.

Foreign supplier identifying 

information is permitted as the only 

supplier identifier if the product is 

imported for use in the importer’s 

own workplace.

The address must be either a mailing address (PO Box may be used) or the 

physical location of the company.
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Label comparison for shipped containers

Requirement

United States Hazard 

Communication Standard

(HCS) 2012

Canadian Hazardous 

Products Regulations

(HPR)

Layout No graphic layout requirements. 

Required pictogram(s), signal word, and hazard statement(s) must be 

grouped together. 

Language All information must be in English. All information must appear in 

English and French.

Other languages are permitted.

Legibility The label must be legible without the use of any device other than 

corrective lenses.

Application requirements The label must be clearly and 

prominently displayed on the 

immediate container.

The label must be clearly and 

prominently displayed on a surface 

that is visible under normal 

conditions of use.

Durability Under normal conditions of 

transport and use, the label must 

remain affixed to, printed or 

written on, or attached to the 

immediate container and remain 

legible (e.g., not torn, defaced, 

destroyed).

Under normal conditions of 

transport and use, the label must 

remain affixed to, printed or written 

on, or attached to the product or its

container and remain legible.

The exemption for small capacity 

containers (3 ml or less) allows for a 

removable label in situations where 

the label may interfere with the 

normal use of the product. In this 

case, the label is not required to 

remain attached to the hazardous 

product during normal conditions 

of use. 
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Label comparison for shipped containers

Requirement

United States Hazard 

Communication Standard

(HCS) 2012

Canadian Hazardous 

Products Regulations

(HPR)

Supplemental information If a chemical mixture is classified 

as acutely toxic for a particular 

route of exposure and contains 

ingredients of unknown acute 

toxicity for that particular route, 

then the following statement is 

required on the label: “X percent 

of the mixture consists of 

ingredient(s) of unknown acute 

toxicity.”

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Supplemental information is 

allowed to be on the label as long 

as it does not contradict or cast 

doubt on the required label 

information. 

If the product is classified as an 

acute toxicant based on

ingredient(s) for which the acute 

toxicity is known and the product 

contains ingredients of unknown 

acute toxicity, the following 

statement is required: 

“[Insert the total concentration in 

percentage of ingredients with 

unknown acute toxicity] % of the

mixture consists of an ingredient or 

ingredients of unknown acute 

toxicity”. The route of exposure 

should be included in the statement 

and the statement is required only 

for the route(s) of exposure with 

respect to which the hazardous 

product is classified.

If a hazardous product is classified 

as an acute toxicant and, upon 

contact with water, it releases a 

toxic gas that meets the 

classification criteria for WaterActivated Toxicity, then a 

supplemental hazard statement is 

required to indicate that, in contact 

with water, the product releases 

gases which are fatal, toxic, or 

harmful if inhaled.

 

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Classifiers may present the unknown acute toxicity information on ingredients either as a single statement or as multiple 

statements, where routes are differentiated. If there is acute toxicity by more than one route of exposure and the classifier

chooses to provide one statement, then the route with the highest total percentage unknown toxicity from one or more 

relevant ingredients will be used in the statement.
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Label comparison for shipped containers

Requirement

United States Hazard 

Communication Standard

(HCS) 2012

Canadian Hazardous 

Products Regulations

(HPR)

Other requirements/

obligations

Sale and import is prohibited if the 

product or its container has affixed

to, printed on, or attached to it 

information about the product that 

is false, misleading, or likely to 

create an erroneous impression,

with respect to the information that 

is required to be included in a label 

or safety data sheet for that 

hazardous product.