On March 6, 2026, Health Canada published a notice clarifying requirements for fragrance allergen reporting in cosmetics. The notice provides a clear interpretation of the existing Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (SOR/2024-63), without changing the regulations themselves.

As is well known, cosmetic companies must list allergens in the Cosmetic Notification Form (CNF), the official form used to declare ingredients for products placed on the Canadian market. Until recently, however, it was unclear whether concentrations of fragrance allergens had to be reported. Following industry feedback, Health Canada clarified its position: while allergens must still be declared in the CNF, providing their concentration is now generally optional.

This introduces significant flexibility for companies without affecting existing labelling obligations.
However, this flexibility does not apply to substances already restricted under the Cosmetic Ingredient Hotlist (a list of prohibited or restricted cosmetic ingredients maintained by Health Canada), for which concentration data may still be required depending on the applicable Hotlist restriction.

Key points

• Fragrance allergens must appear on labels when exceeding 0.01% in rinse-off products or 0.001% in leave-on products.
• All allergens must still be listed in the CNF.
• Concentration reporting is optional for most allergens, but remains mandatory for those restricted under the Hotlist.

What matters

• Optional concentration reporting: most allergens can be notified in CNF without specifying concentrations or ranges.
• Hotlist exception: restricted allergens (e.g., Eucalyptus, Camphor, Methyl Salicylate) still require concentration data.
• CNF updates: the revised CNF expected in Summer 2026 will allow entries without concentration information.
• Interim approach: Companies lacking concentration data may wait to update CNFs until the new form is available.
• Guidance update: an updated Guide for Cosmetic Notifications will be released alongside the new CNF.

This clarification aligns with statements made during Health Canada’s Fall Regulatory Workshop (November 2025), where the agency acknowledged industry concerns and signaled a more flexible interpretation.

Implementation timeline

According to the Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (SOR/2024-63) and related guidance, the implementation of fragrance allergen labelling follows a phased approach:

• From April 12, 2026: new and existing cosmetics must declare the 24 fragrance allergens in List 1 (Appendix 1) when above 0.01% in rinse-off products and 0.001% in leave-on products.
• From August 1, 2026: new cosmetics must declare allergens listed in List 2 (Appendix 1 of the Cosmetic Labelling Guide for Industry) above the same thresholds.
• From August 1, 2028: existing products must comply with List 2 requirements.

In addition, Health Canada has indicated that a one-year compliance promotion period will follow the entry into force of the new requirements, with risk-based enforcement expected from April 2027, as outlined in its March 2026 notice.

Implications for manufacturers

Companies placing cosmetics on the Canadian market should:

• Review ingredient lists and ensure correct allergen labelling.
• Assess availability of concentration data across the supply chain.
• Plan CNF updates in line with the new form and regulatory timeline.
• Monitor upcoming Health Canada guidance and tools.

Although concentration reporting is now optional in most cases, allergens must still be consistently declared in both the CNF and on product labels. Early planning can help minimise compliance risks as enforcement approaches.

>>> Complife supports cosmetic companies with analytical testing, allergen quantification, and strategic regulatory consulting, to ensure full compliance with Health Canada requirements.

Sources

• Health Canada official notice – Reporting of Fragrance Allergen Concentrations Declared “Optional” by Health Canada – Posted March 10, 2026 (refers to notice of March 6, 2026)
• Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (SOR/2024-63)
• Labelling of Cosmetics – Health Canada
• Guide for Cosmetic Notifications – Health Canada
• Cosmetic Ingredient Hotlist – Health Canada
• Industry Guide for the Labelling of Cosmetics – Health Canada