On March 9, 2026, Health Canada announced a pivotal adjustment to the upcoming fragrance allergen disclosure requirements for cosmetics, offering significantly greater flexibility to the industry.
Core Change: Concentration Reporting Moves from “Mandatory” to “Optional”
- Relaxation of Notification Requirements: In the Cosmetic Notification Form (CNF), the provision of specific concentration information for most fragrance allergens will no longer be mandatory. Companies may now choose to provide this data on a voluntary basis.
- Labeling Compliance Remains Unchanged: Despite the easing of concentration reporting in the CNF, the baseline for product labeling remains strict. If a fragrance allergen exceeds the established thresholds (>0.01% for rinse-off products and >0.001% for leave-on products), companies must clearly list these allergens in the ingredient deck on the product label and include them as individual ingredients in the CNF.
Important Exception: Concentrations Still Required for “Hotlist” Ingredients
Please note that this “relaxation” policy does not apply to all substances!
If a fragrance allergen is also classified as a restricted substance on the Cosmetic Ingredient Hotlist, and its restriction is tied to specific concentration limits (e.g., Eucalyptus, Camphor, Methyl Salicylate), companies are still mandated to provide the exact concentration or the corresponding concentration range code in the CNF.
Effective Date and Enforcement Timeline
- April 11, 2026: Regulations officially come into effect.
- April 12, 2026 – April 11, 2027: Transition period focused on “compliance promotion” and guidance.
- From April 12, 2027: Standard risk-based enforcement will commence.
This provides businesses with a one-year “buffer period” to adapt their internal processes to the new requirements.
Next Steps for Businesses
Health Canada expects to update the CNF during the next system upgrade to allow for the submission of specific fragrance allergens without requiring a concentration value. The Guide for Completing Cosmetic Notification Forms will be updated simultaneously.
- Before the system update: If your company already possesses the concentration information, the authorities encourage you to continue reporting it (ensure the “Fragrance Allergen” checkbox is selected).
- If supplier concentration data is currently unavailable: Companies may wait for the release of the revised CNF before submitting their updated notifications.
