When Health Canada amended the Cosmetic Regulations to introduce fragrance allergen disclosure requirements, the industry pushed back fast. The fragrance allergen concentration requirements, specifically the obligation to report exact concentrations or range codes on the Cosmetic Notification Form (CNF), put manufacturers in a difficult position.
Suppliers were reluctant to share proprietary formulation data, and for companies managing multiple SKUs with complex fragrance blends, the administrative and commercial weight of that requirement was hard to absorb.
Health Canada has since responded. If you manage cosmetics compliance for your organisation, here is what changed and what still needs to be in place before April 11, 2026.
What the Original Regulation Required
The amended Cosmetic Regulations established that certain fragrance allergens must be disclosed on product labels when present above a specified threshold: 0.01% in rinse-off products and 0.001% in leave-on products. The amendments also required that both the presence and the concentration of those allergens be reported on the CNF, either as an exact figure or a range code.
That concentration-reporting piece is where industry concern concentrated. Disclosing formulation data through a government notification form raised legitimate questions about the security of proprietary information, particularly for suppliers working across competitive categories.
Concentration Reporting on the CNF Is Now Largely Optional
Health Canada has confirmed it will not be amending the Cosmetic Regulations. Instead, the program is offering flexibility in how the concentration requirement is interpreted for CNF purposes. For most fragrance allergens, including the concentration or range code on the CNF is now optional.
What has not changed: fragrance allergens must still be listed as separate, individual ingredients on the CNF, and they must still be disclosed on product labels when present above the applicable thresholds. The flexibility applies specifically to the concentration data field, not to the allergen listing itself.
The Hotlist Exception: Where Concentration Reporting Remains Required
There is an important exception. If a fragrance allergen is also listed as a restricted ingredient on the Cosmetic Ingredient Hotlist at a specific concentration limit, reporting the concentration or range code on the CNF may still be mandatory. Health Canada has named eucalyptus, camphor, and methyl salicylate as examples where this applies.
A product with a complex fragrance profile may include some allergens where concentration reporting is optional and others where it remains required. Your compliance process needs to account for both categories, which means reviewing the Hotlist conditions for your specific ingredients before assuming the relaxed approach applies across the board.
Timelines and Enforcement
The labelling requirement comes into force on April 11, 2026. Health Canada has outlined a phased enforcement approach for CNF obligations:
- From April 12, 2026 to April 11, 2027, the focus will be on compliance promotion, consistent with the departmental compliance and enforcement framework.
- From April 12, 2027 onwards, risk-based enforcement will follow standard program guidance.
The phased approach applies to CNF enforcement, not to labelling. Fragrance allergens must appear on your ingredient list as required on April 11, 2026. That deadline holds.
The current CNF form still requires a concentration figure when ingredients are entered. A revised form is expected that will allow fragrance allergen entries without that data, but it has not been published yet. In the interim, use the “Fragrance Allergen” checkbox on the current form so the concentration is not counted toward the total lower concentration.
Once the revised form is available, Health Canada will notify subscribers through the Cosmetics Mailing List. For labelling specifics, Health Canada’s cosmetic labelling guidance covers how fragrance allergens must appear within the ingredient list.
Key Takeaways
- Concentration reporting for most fragrance allergens on the CNF is now optional, but allergens must still be listed individually on the form and disclosed on labels above applicable thresholds.
- If a fragrance allergen is also restricted on the Cosmetic Ingredient Hotlist at a specific concentration, the concentration or range code may still be mandatory on the CNF.
- The labelling requirement is in force as of April 11, 2026, with compliance promotion running through April 2027 before risk-based enforcement begins.
- Use the “Fragrance Allergen” checkbox on the current CNF until the revised form is published.
- Subscribe to Health Canada’s Cosmetics Mailing List to receive updates when the new form and revised Cosmetic Notification Guide are released.
Frequently Asked Questions
Does the labelling obligation still apply even with the CNF changes?
Yes, and this point is easy to conflate. The revised approach applies only to concentration reporting on the CNF, not to labelling. Any fragrance allergen present above the applicable threshold must still be disclosed in the ingredient list on the cosmetic label, per the cosmetic labelling requirements. That requirement is in effect as of April 11, 2026, with no phased grace period.
How do I determine whether a fragrance allergen in my formulation requires concentration data on the CNF?
The starting point is the Cosmetic Ingredient Hotlist. Check whether each fragrance allergen in your formulation appears there as a restricted ingredient, and if so, whether the restriction is tied to a specific concentration limit. Where that condition exists, concentration reporting on the CNF remains required. For allergens not subject to a Hotlist concentration restriction, the data is now optional.
What if I already submitted a CNF that includes fragrance allergens with concentration data?
There is no immediate requirement to amend those submissions. Once Health Canada publishes the revised CNF, manufacturers and importers will be able to update entries that no longer require concentration data. The mailing list notification will confirm when the new form and updated Cosmetic Notification Guide are available. If you are managing a large portfolio, now is a good time to identify which products are affected so you are ready to act when the form drops.
A Practical Path Forward
Health Canada’s revised approach reduces the formulation data burden without weakening the consumer protection intent of the original amendments. Labelling transparency continues as planned, and the allergen listing obligation on the CNF remains.
What has shifted is the requirement that pushed proprietary concentration data into the notification process, which was the specific friction point industry identified. The details still require care. The Hotlist exception matters. The interim CNF process has specific steps. And the labelling deadline does not move.
Quality Smart Solutions works with cosmetic manufacturers and importers through CNF filing, label review, and Hotlist assessment. If you are working through how these changes apply to your portfolio, explore our Cosmetics compliance services or contact our regulatory experts for guidance specific to your situation.
