Canada implementation of new labelling requirements for allergens
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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 |
Author

Christophe Brault-Chevalier
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