With the continuous global rise in cosmetic regulatory transparency, Health Canada has recently implemented significant updates to the Cosmetic Regulations (SOR/2024-63), requiring the disclosure of fragrance allergen information on cosmetic labels. This update not only impacts the Canadian market but also aligns more closely with European Union (EU) regulations. What does this update mean for brands and consumers? Let’s take a look.
Key Requirements and Allergen Disclosure Standards
The primary goal of Canada’s fragrance allergen disclosure is to align with European Union (EU) standards, ensuring that consumers—particularly those with fragrance sensitivities—can clearly identify specific allergens rather than seeing them grouped under the generic terms “Parfum” or “Fragrance.”
According to the new regulations, specific fragrance allergens must be listed individually on the label only when their concentration exceeds the following thresholds:
- Rinse-off products (e.g., shampoos, soaps): Concentration exceeding 0.01%
- Leave-on products (e.g., moisturizers, perfumes): Concentration exceeding 0.001%
The Evolution of Transparency: From “Fragrance” to Precise Disclosure
For years, the term “Fragrance” provided a safeguard for businesses, allowing them to treat specific scent ingredients as trade secrets without disclosing them to consumers. While this practice protected commercial interests, it left allergic consumers unable to identify potential triggers. Canada’s new regulation changes this landscape.
Starting April 12, 2026, all cosmetics containing specific fragrance allergens can no longer rely solely on the generic terms “Parfum” or “Fragrance.” Instead, each allergen must be listed by name individually based on the concentration requirements.
Implementation Timeline
To allow manufacturers sufficient time to adjust labels and formulations, Health Canada is adopting a phased approach for these requirements:
| Phase | Effective Date | Scope | Description of Requirements |
| Phase 1 | April 12, 2026 | New & Existing Products | Disclosure of the initial 24 fragrance allergens. |
| Phase 2 | August 1, 2026 | New Products | Expanded disclosure of over 81 fragrance allergens. |
| Phase 3 | August 1, 2028 | All Products on Market | Full compliance for all inventory, disclosing the expanded list of fragrance allergens. |
Nota: “New products” refer to products entering the market for the first time after the specified date. For products already on the market, there is a grace period following the Phase 1 disclosure until August 1, 2028, by which time all products must reach full compliance.
Summary of Changes
- Label Placement: Required fragrance allergens must be listed in the ingredient list, typically following “Parfum,” in descending order of concentration.
- Notification Requirements: Starting April 12, 2026, all cosmetics containing any of the 24 fragrance allergens must list these allergens individually in the Formulario de notificación de cosméticos.
- Bilingual Requirements: Canada continues to require bilingual labels. If the INCI name is the same in both English and French (as is common for chemical names), only one name needs to be listed.
- Small Packaging: For small products (e.g., eyeliners, lipsticks), manufacturers may use tags, tapes, cards, or provide a website URL where consumers can view the full ingredient list.
Cosmetic Notification Form (CNF) Update Requirements
When selling cosmetics in Canada, manufacturers must submit a Cosmetic Notification Form (CNF) to Health Canada within 10 days of the first sale.
- As of April 12, 2026: If a cosmetic formula contains any fragrance allergens exceeding the threshold, these allergens must be disclosed individually in the CNF ingredient list.
- As of August 1, 2026: The disclosure will expand to over 81 fragrance allergens, and these ingredients can no longer be grouped under the category of “Fragrance.”
Conclusion
This update marks a significant step for Canadian cosmetic regulations toward higher transparency and greater consumer protection. Brands will need to adjust their labels and formulations accordingly, while consumers will gain a clearer understanding of whether the cosmetics they use contain ingredients that may trigger allergies. As Canada gradually converges with global cosmetic regulatory standards, compliance requirements for the industry will become more consistent and streamlined.
