Health Canada has revised its guidance surrounding fragrance allergen reporting in cosmetics, introducing nuanced changes. Most companies will now find that reporting exact allergen concentrations is no longer mandatory in many cases. Fragrance allergens must still be listed in the Cosmetic Notification Form, tho brands can now omit detailed concentration figures. These adjustments, prompted by legislative updates in 2024, bring Canadian regulations closer to those of the European Union.Upcoming deadlines remain, making it crucial for businesses to know which requirements apply to their products and by when.
Summary of Recent Regulatory Changes
Health Canada’s current approach grants more flexibility in how cosmetic brands address fragrance allergen disclosure. Companies must still declare fragrance allergens in the Cosmetic Notification Form. 
Listing allergen concentrations has shifted to an optional step except for substances flagged by the Cosmetic Ingredient hotlist. Hotlist items may still require detailed disclosure to meet regulatory standards.
Prior to 2024, standards were stricter. Earlier regulations forced brands to report allergen concentrations exceeding 0.01% for rinse-off cosmetics and 0.001% for leave-on products in the Cosmetic Notification Form. The law also mandated naming a Responsible Person based in Canada for local compliance oversight.
Harmonizing with the European Union Framework
the most recent changes were made to streamline Canadian requirements with those set by the European Union. This shift alters how allergens in fragrances are disclosed and monitored in finished cosmetic goods.
Canada’s updated allergen list now mirrors the EU’s Annex III, promoting consistency for brands operating in multiple markets.
Critical Timeline for Compliance
Several important dates relate to the new disclosure protocols. On April 11, 2026, mandatory reporting of certain allergens on cosmetic fragrance labels will begin.
As of this date, both new and existing cosmetic items must list the 24 designated fragrance allergens from the EU Annex III, but only if the ingredient content surpasses the specified limits.
By 2027, all cosmetics sold in Canada-whether old or new-must fully comply with these requirements.
Practical Considerations for Cosmetic Brands
In effect, the rules now present a dual approach. Cosmetic companies need to keep reporting the presence of fragrance allergens on the Cosmetic Notification Form, but listing precise concentrations is usually no longer necessary.
Canada’s broader regulatory structure from 2024 remains, emphasizing alignment with EU norms and introducing future labeling milestones. Brands should track these developments to maintain regulatory compliance.
