Workplace Label vs. Supplier Label: When Is Each Required Under WHMIS?

A hazardous product arrives at your workplace in its original container with a detailed WHMIS label. Later, someone pours part of that product into a smaller bottle for use on the shop floor. Another container’s original label becomes stained and difficult to read. Somewhere else in the facility, employees mix a hazardous product on-site.

Do all these containers need the same type of label?

Not necessarily.

Under WHMIS, supplier labels and workplace labels serve different purposes. The type of label you need generally depends on where the product came from, whether it remains in its original container, and how it will be used in the workplace.

Understanding the difference can help you keep hazardous products properly identified and ensure workers have access to the information they need to handle them safely.

Here’s how to determine which label applies in common workplace situations.

Supplier labels are generally provided with hazardous products that are sold, distributed, or imported for use in workplaces. They contain detailed, standardized information about the product and its hazards.

Workplace labels are created and applied within the workplace when certain situations arise, such as when a hazardous product is transferred into another container, produced on-site, or no longer has a readable supplier label.

Here’s a quick comparison:

A supplier label is generally found on the original container in which a hazardous product is received.

If the product remains in that container and the supplier label stays attached, legible, and up to date, you generally do not need to add a workplace label.

The supplier is responsible for preparing and applying a compliant label before providing the hazardous product to the customer. The label must be attached to, printed on, written on, or otherwise affixed to the product or its container. Providing the label separately with shipping documents does not replace the requirement to label the container.

Once the product enters your workplace, your employer is responsible for making sure the supplier label remains present and readable. It must also contain more detailed information than workplace labels: 

• Product identifier
• Initial supplier identifier
• Hazard pictograms, where required
• Signal word, where required
• Hazard statements
• Precautionary statements
• Required supplemental information

Supplier labels must also meet WHMIS language requirements and provide the required information in English and French.

For a complete explanation of these requirements, read our blog: WHMIS Label Requirements in Canada.

A workplace label is generally required when something happens to the product or its original label after it enters the workplace.

There are three common situations where you may need one.

1. A Hazardous Product Is Transferred into Another Container

When a hazardous product is poured or transferred from its original supplier container into another container, the new container generally requires a workplace label.

For example, your facility may purchase an industrial cleaner in a large supplier-labelled drum and transfer smaller quantities into spray bottles for maintenance staff.

Because those bottles no longer carry the original supplier label, workers need another way to identify the product, understand the necessary handling precautions, and locate the applicable SDS.

There are limited exceptions for products transferred for immediate use or kept under the control of the worker who transferred them. We’ll explain those situations in more detail below.

2. A Hazardous Product Is Produced in the Workplace

If your workplace produces a hazardous product and uses it within the same workplace, the employer is generally responsible for preparing and applying a workplace label.

Examples may include:

• Chemical mixtures
• Process blends
• Cleaning solutions prepared on-site
• Hazardous products created during manufacturing

The product must be properly identified so workers understand what it is and how to handle it safely.

3. A Supplier Label Is Missing, Damaged, or Unreadable

Supplier labels can degrade, be damaged, or become illegible over time. If a supplier label is missing or can no longer be read, the container should not continue circulating through the workplace without proper identification.

The employer must take steps to restore the required hazard information. Depending on the circumstances and applicable jurisdiction, this may involve obtaining and applying a replacement supplier label or preparing a workplace label.

Temporary use is one of the most commonly misunderstood areas of workplace labelling. Some people assume that any product transferred into a temporary container is exempt from workplace-label requirements. That isn’t the case.

However, a full workplace label may not be required when a hazardous product is transferred into another container and used immediately by the person who transferred it.

A limited provision may also apply when the product:

• Remains under the control of the person who transferred it
• Will only be used by that person
• Is used during the same work shift

In this situation, the container must still be identified with the product identifier.

If the product will be stored, left unattended, used during a later shift, or handled by another worker, a full workplace label is generally required.

For example, imagine a maintenance worker pours a cleaning chemical into a smaller container, keeps the container with them, and uses all of the product during the same shift. A full workplace label may not be necessary, although the product must still be identified as required.

If that same container is left on a maintenance cart for the next shift, the situation changes. Other workers may encounter or use the product, so a workplace label would generally be required.

Keep in mind that workplace-label requirements are regulated by provincial, territorial, or federal occupational health and safety authorities, and requirements may vary by jurisdiction.

However, you can use this chart as a general starting point when deciding which label applies.

The difference between supplier and workplace labels becomes much easier to understand when you focus on how the product is packaged and used.

If a hazardous product remains in its original container and the supplier label is attached and readable, retain the supplier label.

If the product is transferred into another container, is produced within the workplace, or no longer has a readable supplier label, a workplace label is generally required. Limited provisions may apply when a transferred product is used immediately or remains under the control of the person who transferred it.

At Industrial Nameplates, we manufacture durable custom labels for industrial and workplace applications. If you need labels designed to remain clear, securely attached, and readable in demanding environments, give us a call at 403-930-5543, email sales@industrialnameplates.ca, or contact us, and we’ll help you make the right decision.