On 6 March 2026, Health Canada notified stakeholders via its mailing list of a revised approach to fragrance allergen disclosure for cosmetics. While fragrance allergens must still be included in the Cosmetic Notification Form (CNF), brands are no longer required to declare the individual allergen concentrations in most cases.
Background: 2024 amendments to Canada’s Cosmetic Regulations
In October 2024, Canada amended its Cosmetic Regulations, introducing additional requirements that further align the Canadian regulatory framework with that of the European Union. Key changes included:
- Mandatory appointment of a Canada-based Responsible Person
- New requirements for fragrance allergen labelling and notification disclosure
Initially, Health Canada announced that the full concentration of fragrance allergens would need to be disclosed in the Cosmetic Notification Form when present above:
- 0.01% in rinse-off products
- 0.001% in leave-on products
However, Health Canada has now revised its position. Reporting the concentration of most fragrance allergens on the Cosmetic Notification Form will be optional. Concentration disclosure may only be mandatory for allergens that are restricted under Canada’s Cosmetic Ingredient Hotlist.
Deadlines for allergens disclosure compliance
The requirement to disclose certain fragrance allergens on cosmetic labels will come into force on 11 April 2026. Health Canada has directly adopted the European Union Annex III fragrance allergen list.
The compliance deadlines are as follows:
- 11 April 2026: New and existing cosmetics must disclose the original 24 fragrance allergens listed in Annex III of the EU Cosmetic Regulation when present at concentrations greater than 0.01% in rinse-off products and 0.001% in leave-on products.
- 1 August 2026: New cosmetics must disclose the 56 additional fragrance allergens recently added to Annex III when present above the same thresholds.
- 11 April 2027: Existing cosmetics must disclose the 56 additional fragrance allergens recently added to Annex III when present above the same thresholds.
European Union framework deadlines
From 31 July 2026, the 56 additional fragrance allergens added to Annex III of the EU Cosmetic Regulation in 2023 must be disclosed on the ingredient lists of cosmetic products placed on the European Union market when present above the same threshold.
For a complete overview of cosmetic regulatory deadlines in 2026, please refer to our 2026 Timetable for Cosmetics Businesses.
Do you have questions on compliance of cosmetics in the EU, UK, USA, and Canada? Contact us here or at coslaw@obelis.net.
References
European Commission. (2023). Commission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards labelling of fragrance allergens in cosmetic products. Retrieved on 27/07/2023.
Government of Canada. (2025). Industry Guide for the labelling of cosmetics. Retrieved on 01/12/2025.
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