Canada implementation of new labelling requirements for allergens

Canada implementation of new labelling requirements for allergens

The Canadian Cosmetic Regulations were amended in April 2024 (SOR/2024-63), introducing new allergen labelling requirements for cosmetic products. This information letter outlines the upcoming compliance deadlines and provides details on specific requirements related to grouped allergens, small packages and notification obligations.

Scientific and Regulatory Background

Fragrance ingredients are a frequent cause of cosmetic-related contact allergies. Although generally safe, some individuals may develop allergic contact dermatitis (ACD) after repeated exposure to specific fragrance allergens.

Canadian labels have traditionally used the generic term “parfum” to indicate fragrance content, a practice that offered limited information to individuals with fragrance sensitivities. The 2024 regulatory amendments now strengthen labelling rules by requiring fragrance allergens to be listed.

The amended Regulations incorporate, by reference, the list of fragrance allergens in Annex III of the EU Cosmetic Products Regulation, along with its transition periods for future updates. This promotes regulatory alignment with the EU.

The impact of new allergens labelling requirements

The amended Regulations affect several areas, including 1) Deadlines for allergen disclosure, 2) Rules for naming grouped allergens, 3) Labelling flexibility for small packages and 4) Updates to the cosmetic notification form.

1. Deadlines for allergen disclosure

Fragrance allergens must be listed on cosmetic labels when present above 0.01% in rinse-off products and 0.001% in leave-on products, consistent with EU thresholds. In line with this alignment, it is worth recalling that in July 2023 the European Commission expanded the list of reportable fragrance allergens from 24 (List 1) to 81 entries (List 2).

Canada’s deadlines for implementing these disclosures are as follows:

Deadline Products concerned Allergens to be disclosed (see Annex I for the lists) Condition
April 12, 2026         Cosmetics placed on the market and already on the market Must disclose allergens from List 1

When fragrance allergens are present at concentration greater than

• 0.01% in rinse off products

• 0.001% in leave on products

August 1, 2026 Cosmetics placed on the market Must disclose allergens from List 2
August 1, 2028 Cosmetics available on shelves Must disclose allergens from List 2

2. Rules for naming grouped allergens

Certain fragrance allergen listings consist of multiple substances and are treated as grouped allergens. In these cases, the designated group name must appear in the ingredient list. Disclosure is required when the combined concentration of all substances within that group exceeds 0.01% in rinse-off products and 0.001% in leave-on products.

Individual substances within a grouped entry may be listed voluntarily as additional information, but this is not mandatory.

For example, if a leave-on product contains 0.0008% of Rosa Damascena Flower Oil and 0.002% of Rosa Damascena Flower Extract, the total exceeds the disclosure threshold. The group name Rose Flower Oil/Extract must therefore be included on the label, and the individual component names may be added if desired.

3. Labelling flexibility for small packages

Small containers, such as those for lipsticks, eyeliners or balms, may be too limited in space to display a legible ingredient list. In these cases, the list can be provided on a tag, tape or card attached to the product or placed on the outer label.

As another option when space is insufficient, the ingredient list can be disclosed on a website, as long as the product label includes a bilingual statement directing consumers to the web address.

Example of an acceptable bilingual statement:

“For the list of ingredients – Pour la liste des ingrédients: www.websitename.ca”.

4. Updates to the Cosmetic Notification Form (CNF)

As a result of these amendments, the information about the presence and concentration of fragrance allergens also needs to be reflected in the cosmetic notification. Since allergens are considered to be ingredients, manufacturers and importers must indicate them in section 5 of the CNF.

According to a recent update, Health Canada announced during the Cosmetics Alliance Canada regulatory conference that the concentration information will now be an optional to report in the CNF. The CNF and related guidance will be updated to reflect this change in the coming months.

What is next?

Allergen reports must include all cosmetic allergens — both those already listed and the newly added ones — for every fragrance and for natural materials such as essential oils and certain extracts. This information is necessary to prepare ingredient lists that comply with the amended Canadian Cosmetic Regulations in advance of the April 12 and August 1, 2026, deadlines.

Annex I – List 1 and 2 - INCI Name of fragrance allergen

List 1 – Regular

Fragrance allergens required to appear in the ingredient list, when present above the specified concentration, effective April 12, 2026.

List 2 – Expanded

Fragrance allergens required to appear in the ingredient list, when present above the specified concentration, effective August 1, 2026 for new products and August 1, 2028 for existing products.

* allergens from the regular list

1. Amyl Cinnamal
2. Amylcinnamyl Alcohol
3. Anise Alcohol
4. Benzyl Alcohol
5. Benzyl Benzoate
6. Benzyl Cinnamate
7. Benzyl Salicylate
8. Cinnamal
9. Cinnamyl Alcohol
10. Citral
11. Citronellol
12. Coumarin
13. Eugenol
14. Farnesol
15. Geraniol
16. Hexyl Cinnamal
17. Hydroxycitronellal
18. Isoeugenol
19. Alpha Isomethyl Ionone
20. Limonene
21. Linalool
22. Methyl 2 Octynoate
23. Evernia Furfuracea (Treemoss) Extract
24. Evernia Prunastri (Oakmoss) Extract
1. Acetyl Cedrene
2. Amyl Cinnamal *
3. Amylcinnamyl Alcohol *
4. Amyl Salicylate
5. Anethole
6. Anise Alcohol *
7. Benzaldehyde
8. Benzyl Alcohol *
9. Benzyl Benzoate *
10. Benzyl Cinnamate *
11. Benzyl Salicylate *
12. Camphor
13. Beta Caryophyllene
14. Carvone
15. Cinnamal *
16. Cinnamyl Alcohol *
17. Citral; Geranial; Neral (Citral shall be indicated)
18. Citronellol *
19. Coumarin *
20. Rose Ketones group
21. Dimethyl Phenethyl Acetate
22. Eugenol *
23. Eugenyl Acetate
24. Farnesol *
25. Geraniol *
26. Geranyl Acetate
27. Hexadecanolactone
28. Hexamethylindanopyran
29. Hexyl Cinnamal *
30. Hydroxycitronellal *
31. Isoeugenol *
32. Isoeugenyl Acetate
33. Alpha Isomethyl Ionone *
34. Limonene *
35. Linalool *
36. Linalyl Acetate
37. Menthol
38. 6 Methyl Coumarin
39. Methyl 2 Octynoate *
40. Methyl Salicylate
41. Pinene
42. 3 Propylidenephthalide
43. Salicylaldehyde
44. Santalol
45. Sclareol
46. Terpineol
47. Alpha Terpinene
48. Terpinolene
49. Tetramethyl Acetyloctahydronaphthalenes
50. Trimethylbenzenepropanol
51. Trimethylcyclopentenyl Methylisopentenol
52. Vanillin
53. Cananga Odorata Oil Extract group
54. Cedrus Atlantica Oil Extract group
55. Cinnamomum Cassia Leaf Oil
56. Cinnamomum Zeylanicum Bark Oil
57. Citrus Aurantium Flower Oil group
58. Citrus Aurantium Peel Oil group
59. Citrus Aurantium Bergamia Peel Oil
60. Citrus Limon Peel Oil
61. Lemongrass Oil group
62. Eucalyptus Globulus Oil group
63. Eugenia Caryophyllus Oil group
64. Evernia Furfuracea Extract *
65. Evernia Prunastri Extract *
66. Jasmine Oil Extract group
67. Juniperus Virginiana Oil group
68. Laurus Nobilis Leaf Oil
69. Lavandula Oil Extract group
70. Mentha Piperita Oil
71. Mentha Viridis Leaf Oil
72. Myroxylon Pereirae Oil Extract group
73. Narcissus Extract group
74. Pelargonium Graveolens Flower Oil
75. Pinus Mugo group
76. Pinus Pumila group
77. Pogostemon Cablin Oil
78. Rose Flower Oil Extract group
79. Santalum Album Oil
80. Turpentine
81. Lippia Citriodora Absolute

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