Quantum Logo
PUBLISHED ON
July 16, 2025

Global Safety Data Sheet Compliance: Key Differences by Country

Is one Safety Data Sheet (SDS) valid worldwide under the Globally Harmonized System (GHS)?

The short answer is no.

Although GHS was created to harmonize chemical hazard communication globally, each country adopts it differently, which means SDSs still vary significantly between jurisdictions like Canada, the United States, the European Union, and the Asia-Pacific regions.

In this article, we explain why a single SDS doesn’t meet global compliance needs—and what your organization must know to avoid legal risks, rejected imports, and regulatory fines.

What Is GHS and Why Doesn’t It Fully Harmonize SDSs?

The Globally Harmonized System (GHS)was developed by the United Nations to standardize how chemical hazards are classified and communicated, especially through¡

  • Labels
  • Pictograms
  • Signal Words
  • Safety Data Sheets (SDSs)

But here's the catch:

GHS is not legally binding
—it’s a guideline, not a regulation.

Each country chooses which GHS revision to adopt, and adds its own regulatory requirements (like transportation, environmental laws, and toxicological thresholds).

10 Key Reasons SDSs Differ Between Countries

1. Countries Adopt Different GHS Revisions

GHS evolves over time.

  • Canada uses Revision 7 and certain provisions of 8
  • USA uses Revision 7
  • EU follows a hybrid with additional REACH regulations

This creates discrepancies in hazard classification, labelling requirements, and SDS formatting.

2. Transportation and Environmental Laws Differ by Country

SDSs must also align with local laws governing:

  • Transport (e.g., TDG in Canada, DOT in the U.S.)
  • Environmental protection
  • Occupational exposure limits

These are not part of GHS and must be accounted for by region.

3. Local Regulations Are Constantly Changing

Regulations are updated frequently. For example:

  • After Canada’s Lac-Mégantic rail disaster, TDG regulations changed dramatically.
  • SDS authors must stay current or risk non-compliance.

4. Different Hazard Classifications for the Same Substance

The same chemical can be classified differently in each country due to:

  • Variations in adopted GHS revisions
  • National scientific assessments
  • Country-specific exposure thresholds

5. Toxicology Research Is Always Evolving

New toxicological data emerge daily.

What was once considered “safe” may later be reclassified as hazardous based on updated human or environmental studies.

6. Exposure Scenarios Can’t Always Be Predicted

An SDS must account for realistic workplace exposure risks, which can vary based on:

  • Industry
  • Use case
  • Process and frequency

Accurate SDS authoring involves collaboration with the product owner to predict exposure paths.

7. Exposure Cut-Offs Vary by Country

Different countries define “hazardous concentration levels” differently.
What qualifies as a reportable concentration in Canada might not in Europe—or vice versa.

8. Ingredients May Be Restricted or Banned

  • In Canada, only chemicals on the Domestic Substances  List (DSL) are allowed for commercial use (approx. 28,000 substances).
  • A product ingredient legal in the U.S. may be prohibited in  Canada or the EU.

9. Ingredient Concentration Ranges Are Treated Differently

Some countries permit wider concentration ranges; others require exact percentages.
Misalignment here can lead to rejected SDSs and legal challenges.

10. Confidential Business Information (CBI) Protections Differ

Each country has different rules for withholding proprietary ingredient information.
Professionally authored SDSs help protect intellectual property while maintaining compliance.

SDSs Must Be Routinely Updated

SDSs aren’t “set it and forget it” documents.

SDS Authoring Responsibility and Updates in the USA

In the USA, the Hazard Communication Standard (HCS), requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) for each hazardous chemical to downstream users to communicate information on these hazards.  If a manufacturer, importer, or employer learns of Significant New Information about a chemical's hazards or safe handling, the SDS must be updated. 

Timelines for Updates in USA:

SDS Updates: Within three months of becoming aware of the new information. 

Label Updates: Within six months of the SDS update. 

"Significant New Data"Definition in USA: This refers to new information that changes the hazard classification or alters how to protect against the hazards. 

SDS Authoring Responsibility and Updates in Canada

In Canada, Safety Data Sheets (SDSs) for hazardous products must be updated when new, significant information about the product becomes available that changes its classification or safe handling procedures. This significant new data triggers a 90-day update requirement for suppliers. While there's no longer a mandatory three-year update, employers may have additional requirements within their specific jurisdictions, like updating SDSs in the workplace. 

Significant New Data Deadline for Update in Canada:

Suppliers must update SDSs within 90 days of becoming aware of "significant new data" that affects hazard classification or safe handling/storage. 

No Mandatory 3-Year Review: The previous three-year review requirement for SDSs has been eliminated. 

Deadline for Communication to Purchasers in Canada:

If a product is sold or imported within the 90-day period after significant new data becomes available, the supplier must communicate the changes to the purchaser. 

Continuous Review: Suppliers in Canada are expected to continuously review and update SDSs as new information becomes available. If new toxicological, regulatory, or usage information becomes available, the SDS must be updated—it’s a legal requirement, not a suggestion.

Why Work with a Professional SDS Author?

A qualified SDS author ensures your documents

  • Meet country-specific GHS versions
  • Integrate transportation, environmental, and health regulations
  • Are scientifically accurate and defensible
  • Protect your business from compliance risks and product delays

Trust Quantum SDS for Global SDS Authoring

With over 30 years of expertise, QuantumSDS help companies navigate:

  • Multi-country SDS compliance
  • WHMIS, HazCom, REACH, TDG, DOT, and more
  • Confidential Business Information protections
  • SDS authoring in 43 languages for global distribution

Ready to Author or Update Your SDSs?

Don’t risk rejection at the border or non-compliance in your market.


Let our team of registered SDS authors keep your products legally compliant—everywhere you do business.

Contact Quantum SDS for a Quote

Get in touch today to ensure your Safety Data Sheets are updated to the new WHMIS compliance standards. With Quantum’s authoring expertise and smart software solutions, compliance doesn’t have to be complicated.

Contact Us
Quantum SDS
Copyright 2025 Quantum SDS. All rights reserved
A Quadshift company