Health Canada has introduced new requirements regarding the disclosure of fragrance allergens in cosmetic products sold in Canada.
These changes aim to improve transparency for consumers who may be sensitive to certain fragrance ingredients.
Under the updated Cosmetic Regulations, certain fragrance allergens must be disclosed on cosmetic product labels when present above specific concentration thresholds.
At the same time, Health Canada has recently clarified expectations regarding how these allergens must be reported in the Cosmetic Notification Form (CNF), introducing additional flexibility for industry.
This article explains the new requirements, the reporting expectations, and the compliance timeline companies should be aware of.
New fragrance allergen labeling requirements
Under the amended Cosmetic Regulations, certain fragrance allergens must be listed on cosmetic product labels when present above the following thresholds:
- 0.01% in rinse-off products
- 0.001% in leave-on products
These thresholds are consistent with international approaches intended to help consumers identify substances that may trigger allergic reactions.
Additional information regarding cosmetic labeling requirements can be found in Health Canada's guidance on cosmetic labeling:
Changes to CNF reporting expectations
Following the publication of the amended regulations, Health Canada received feedback from industry regarding the challenges of disclosing the exact concentration of fragrance allergens in cosmetic formulations.
Some companies indicated that obtaining this information from fragrance suppliers could raise concerns related to confidential business information.
In response, Health Canada has clarified that the concentration of certain fragrance allergens in the Cosmetic Notification Form will be optional.
However, fragrance allergens must still be:
- declared as individual ingredients in the CNF
- disclosed on product labels when present above the regulatory thresholds
Important exception: restricted ingredients
An important exception applies when a fragrance allergen is also subject to restrictions under the Cosmetic Ingredient Hotlist.
In these cases, the concentration or concentration range may still need to be provided in the Cosmetic Notification Form.
Examples include substances such as:
- eucalyptus
- camphor
- methyl salicylate
Companies should therefore verify whether fragrance allergens appearing in their formulations are also listed in the Cosmetic Ingredient Hotlist.
Compliance timeline
The new fragrance allergen disclosure requirement will enter into force on April 12, 2026.
Health Canada has also indicated that enforcement will follow a phased approach:
April 12, 2026 – April 11, 2027
Focus on promoting compliance and supporting regulated parties.
From April 12, 2027
Compliance and enforcement activities will follow a risk-based approach.
More information about Health Canada's compliance approach is available here:
Updates to the Cosmetic Notification Form
Health Canada has also indicated that the Cosmetic Notification Form will be updated to allow fragrance allergens to be declared without requiring concentration information.
Until the updated form is released, companies are encouraged to provide the concentration or concentration range if this information is available.
Conclusion
The new fragrance allergen disclosure requirements represent an important step in improving transparency for consumers while maintaining flexibility for industry.
For companies selling cosmetic products in Canada, preparation should focus on:
- reviewing fragrance compositions
- identifying allergens subject to disclosure
- verifying labeling compliance
- ensuring CNF submissions are aligned with the updated expectations
With the April 2026 deadline approaching, early preparation will help avoid regulatory issues and ensure smooth compliance.
Going further
If you have questions about how these fragrance allergen requirements apply to your cosmetic products or notification submissions, our regulatory team can support you.
You can also subscribe to our cosmetics regulatory newsletter to stay informed about regulatory developments in Canada, the United States, and Europe.
👉 Contact us | 👉 Subscribe to the newsletter
Additional official resources are available through Health Canada's cosmetics updates service:
https://www.canada.ca/fr/sante-canada/services/cosmetiques/abonnement.html
Health Canada has introduced new requirements regarding the disclosure of fragrance allergens in cosmetic products sold in Canada.
These changes aim to improve transparency for consumers who may be sensitive to certain fragrance ingredients.
Under the updated Cosmetic Regulations, certain fragrance allergens must be disclosed on cosmetic product labels when present above specific concentration thresholds.
At the same time, Health Canada has recently clarified expectations regarding how these allergens must be reported in the Cosmetic Notification Form (CNF), introducing additional flexibility for industry.
This article explains the new requirements, the reporting expectations, and the compliance timeline companies should be aware of.
New fragrance allergen labeling requirements
Under the amended Cosmetic Regulations, certain fragrance allergens must be listed on cosmetic product labels when present above the following thresholds:
- 0.01% in rinse-off products
- 0.001% in leave-on products
These thresholds are consistent with international approaches intended to help consumers identify substances that may trigger allergic reactions.
Additional information regarding cosmetic labeling requirements can be found in Health Canada's guidance on cosmetic labeling:
Changes to CNF reporting expectations
Following the publication of the amended regulations, Health Canada received feedback from industry regarding the challenges of disclosing the exact concentration of fragrance allergens in cosmetic formulations.
Some companies indicated that obtaining this information from fragrance suppliers could raise concerns related to confidential business information.
In response, Health Canada has clarified that the concentration of certain fragrance allergens in the Cosmetic Notification Form will be optional.
However, fragrance allergens must still be:
- declared as individual ingredients in the CNF
- disclosed on product labels when present above the regulatory thresholds
Important exception: restricted ingredients
An important exception applies when a fragrance allergen is also subject to restrictions under the Cosmetic Ingredient Hotlist.
In these cases, the concentration or concentration range may still need to be provided in the Cosmetic Notification Form.
Examples include substances such as:
- eucalyptus
- camphor
- methyl salicylate
Companies should therefore verify whether fragrance allergens appearing in their formulations are also listed in the Cosmetic Ingredient Hotlist.
Compliance timeline
The new fragrance allergen disclosure requirement will enter into force on April 12, 2026.
Health Canada has also indicated that enforcement will follow a phased approach:
April 12, 2026 – April 11, 2027
Focus on promoting compliance and supporting regulated parties.
From April 12, 2027
Compliance and enforcement activities will follow a risk-based approach.
More information about Health Canada's compliance approach is available here:
Updates to the Cosmetic Notification Form
Health Canada has also indicated that the Cosmetic Notification Form will be updated to allow fragrance allergens to be declared without requiring concentration information.
Until the updated form is released, companies are encouraged to provide the concentration or concentration range if this information is available.
Conclusion
The new fragrance allergen disclosure requirements represent an important step in improving transparency for consumers while maintaining flexibility for industry.
For companies selling cosmetic products in Canada, preparation should focus on:
- reviewing fragrance compositions
- identifying allergens subject to disclosure
- verifying labeling compliance
- ensuring CNF submissions are aligned with the updated expectations
With the April 2026 deadline approaching, early preparation will help avoid regulatory issues and ensure smooth compliance.
Going further
If you have questions about how these fragrance allergen requirements apply to your cosmetic products or notification submissions, our regulatory team can support you.
You can also subscribe to our cosmetics regulatory newsletter to stay informed about regulatory developments in Canada, the United States, and Europe.
👉 Contact us | 👉 Subscribe to the newsletter
Additional official resources are available through Health Canada's cosmetics updates service:
https://www.canada.ca/fr/sante-canada/services/cosmetiques/abonnement.html
