Selling cosmetics in Canada? If you’re a brand outside of Canada, there’s an important update you need to know about. Starting March 1, 2025, Health Canada will require that all Cosmetic Notification Forms (CNFs) include a Canadian Agent. If you don’t have one, your product won’t be able to legally hit Canadian shelves.
Whether you’re just starting to explore the Canadian cosmetics market or you’ve been selling here for years, this change could impact your business. Knowing what’s required and why now will help you stay ahead and avoid any regulatory surprises.
In this article, we’ll walk you through exactly what a Canadian Agent for cosmetics does, why it’s becoming mandatory, what happens if you don’t appoint one, and how this compares to the U.S. Responsible Person under MoCRA. Let’s dive in.
What Does a Canadian Agent for Cosmetics Do?
A Canadian Agent acts as the official point of contact between Health Canada and foreign cosmetic companies. This agent must have a valid Canadian address, which will be listed on the CNF. The address does not need to appear on the product label, but it must be provided during the CNF process.
The Canadian Agent is responsible for:
- Submitting the CNF to Health Canada.
- Acting as the liaison during audits or regulatory inquiries.
- Ensuring Health Canada has a reliable Canadian-based contact.
Unlike in other industries, the Canadian Agent is not responsible for product safety. Their role is administrative and focused on regulatory communication.
Do You Need to Update CNFs Submitted Before 2025?
If your CNF was submitted before March 1, 2025, you are not required to retroactively update it to include a Canadian Agent. Your original filing will remain valid as it stands. However, keep in mind that if you choose to revise or refile that CNF after March 2025, even for minor corrections or updates, you will then be required to appoint a Canadian Agent.
Because of this, it makes sense to think ahead. If there is a possibility that you will need to make changes to your notification in the future, it is best to have a Canadian Agent ready now so you are prepared.
What Happens If You Do Not Appoint a Canadian Agent?
You cannot submit a CNF without this information starting March 1, 2025. The online form will not allow you to complete the process unless you provide a valid Canadian address. Without a Canadian Agent, your product will be non-compliant and cannot legally be marketed or sold in Canada.
Canadian Agent vs. U.S. Responsible Person under MoCRA
The Canadian Agent requirement is similar in some ways to the U.S. Responsible Person under the Modernization of Cosmetics Regulation Act (MoCRA), but there are key differences.
Canadian Agent | U.S. Responsible Person (MoCRA) |
Administrative role to provide a Canadian address for CNFs | Responsible for product safety, labeling, and adverse event reporting |
Address listed only on CNF, not on product label | Must be identified on the product label |
Liaison with Health Canada | Liaison with the FDA |
If your company operates in both Canada and the U.S., you will need to comply with both sets of rules. To better understand U.S. requirements, check out our MoCRA services page. If you’re looking for official guidance on Canada’s new rules, you can also review Health Canada’s instructions for cosmetic notification submissions here.
Stay Compliant with Quality Smart Solutions
Our regulatory experts can act as your Canadian Agent for Cosmetics and help you navigate Health Canada’s CNF requirements. We also support cosmetic companies with MoCRA compliance and other international regulations.
Ready to get started? Fill out our form for a free consultation with one of our regulatory experts, or visit our Contacts page to reach out to us directly. We will help ensure your products meet both Canadian and U.S. requirements.
Whether you need help with Canadian regulations or U.S. MoCRA compliance, our team is here to guide you every step of the way. You can learn more about how we help companies meet Canadian cosmetic requirements on our Canadian Regulatory Services page. Or, if you’re focusing on entering or staying compliant in the U.S. market, explore our U.S. Cosmetic Compliance services.
