Direct answer: Create a useful bilingual composition section without exposing or inventing data.
Set substance or mixture status
The information structure begins with the product type and exact supplied form.
Link actual supplier grades
Retain trade name, grade, stabilizers, concentration and source SDS beside public identifiers.
Control concentrations and ranges
Store internal values separately from reportable bilingual output and document the selected range basis.
Handle protected information lawfully
A confidentiality claim is a regulated HMIRA process, not a free-text ‘trade secret’ placeholder.
Connect ingredients to hazard decisions
A changed decisive ingredient record should reopen classification, Section 2 and both label languages.
Practical example
A supplier blend is used at 5–8%. The system preserves the range and source record, maps reportable constituents, and does not invent an exact midpoint for classification.
Release checklist
- Confirm product type
- Attach supplier evidence
- Separate exact and reported values
- Review HMIRA status
- Trigger hazard reassessment
Common mistakes
- Treating a blend as a pure CAS substance
- Copying US trade-secret wording
- Publishing unsupported exact values
Frequently asked questions
Must every ingredient be disclosed?
Apply the current HPR disclosure provisions and document the decision.
Can concentration ranges be used?
Use ranges only under the applicable Canadian provisions and with a supportable basis.
Does CBI remove hazard communication?
No. HMIRA protects specified information while critical hazard information remains required.
Should both languages show the same values?
Yes. The bilingual parts should represent one controlled disclosure record.
Primary sources
- Hazardous Products Regulations (current consolidation)
- Health Canada · Guidance on WHMIS supplier requirements
- Health Canada · Confidential business information exemptions
Review notice: CANADIAN REGULATORY AND FRENCH TERMINOLOGY REVIEW REQUIRED BEFORE INDEXING.