Canada TDG Proof of Classification: What It Is, Why It’s Required, and How to Get It Right
For companies shipping dangerous goods in Canada, TDG proof of classification is one of the most misunderstood and most frequently cited compliance requirements under the Transportation of Dangerous Goods (TDG) Regulations. Many consignors assume that classification is covered by an SDS, a carrier, or a third party. In reality, proof of classification is a legal obligation that rests squarely with the consignor.
The TDG Act serves as the legal framework for the transportation of dangerous goods in Canada, establishing the authority and requirements for compliance.
Failure to prepare, retain, and defend a compliant Canada TDG proof of classification can result in shipment delays, enforcement actions, and costly operational disruptions. Understanding what is required, and how to do it correctly, is essential for regulatory compliance and business continuity.
What Is Proof of Classification Under Canada TDG?
Under TDG Part 2 (Classification), proof of classification is the documented evidence demonstrating how a dangerous good was classified. This includes the rationale used to determine the correct:
- UN number
- Proper Shipping Name
- Hazard class or division
- Packing group (if applicable)
TDG proof of classification in Canada must be based on the TDG classification scheme and aligned with the UN Recommendations on the Transport of Dangerous Goods. Importantly, it is not enough to simply state the classification outcome- the documentation must show how the conclusion was reached. Transport Canada may request this documentation at any time, and it must be sufficiently detailed to withstand regulatory scrutiny.
Who Is Responsible for TDG Classification and Proof?
The consignor (the person in Canada who is named in the shipping document and is importing or will import the dangerous good into the country) is legally responsible for ensuring that dangerous goods are correctly classified and that proof of classification documentation exists and is retained.
Classification must be done by, or in consultation with, a person capable of understanding the nature and the properties of the dangerous goods. The competent person responsible for classification must be trained in TDG and understand the goods’ nature and properties. Anyone involved in the shipping, transporting, delivering, receiving, handling, or documenting dangerous goods must complete TDG training to obtain a TDG certificate, which is valid for 3 years. This responsibility cannot be transferred to carriers, freight forwarders, or customers.
A common compliance failure occurs when consignors rely solely on supplier information or assume an SDS satisfies TDG requirements. While supplier data may support classification, it does not eliminate the consignor’s obligation to maintain their own TDG classification documentation that reflects how the product is shipped.
What Documentation Can Be Used as Proof of Classification?
Acceptable proof of classification evidence depends on the product and hazard class but may include:
- Laboratory test reports
- Engineering or technical assessments
- Calculations and evaluation summaries
- Rationale based on UN classification criteria
- Supporting data referenced from an SDS
An SDS can support TDG proof of classification but is insufficient on its own. SDSs are written for workplace hazard communication, not transport classification, and may not address all TDG-specific criteria or shipping configurations.
What the Classification Documentation Must Include Under TDG Regulations
- Proper Shipping Name (as listed in Column 2 of Schedule 1 of the TDG Regulations)
- Primary class (the highest hazard class, determined using the order of precedence in Section 2.8)
- UN number
- Date on which the dangerous goods were classified
If applicable, the consignor must also identify:
- Technical name of the dangerous goods (if applicable)
- Subsidiary class(es) (lower hazard classes)
- Compatibility group (Class 1 explosives only)
- Packing group (I = high danger, II = medium danger, III = low danger)
- Infectious substance category (Class 6.2: Category A or B)
Common Proof of Classification Mistakes That Lead to Non-Compliance
Transport Canada frequently identifies the following issues during inspections and audits:
- No proof of classification on file
- Documentation that does not explain the classification methodology
- Outdated or generic classification records
- Misalignment between SDS hazard information and TDG classification
- Copying classifications from similar products without justification
These gaps can quickly escalate into enforcement actions, shipment refusals, or compliance orders.
Resources for Classification: Where to Find Guidance and Support
Navigating the classification of dangerous goods for transportation requires access to reliable, up-to-date resources and expert support. The foundation for all classification activities in Canada is the Transportation of Dangerous Goods (TDG) Regulations, which outline the procedures for determining whether a substance, product, or organism qualifies as dangerous goods. Part 2 of the TDG Regulations is especially important, as it details the classification methods for identifying the primary class, packing group, and any subsidiary class associated with a material.
TDG proof of classification is not optional; it is a core compliance requirement. Companies shipping dangerous goods in Canada must be prepared to demonstrate how their products were classified, not just what the classification is. A proof of classification reduces regulatory risk, minimizes shipping disruptions, and provides confidence that classification decisions can be defended if challenged.
If you are unsure whether your TDG proof of classification meets Transport Canada expectations, or if you are preparing new products for shipment, our transport consulting team can help. Contact us today for a TDG proof of classification review or development service to ensure your shipments move safely, legally, and without delay.
