Starting April 12, 2026: Health Canada Mandates Fragrance Allergen Disclosure on Cosmetic Labels

Health Canada is implementing new regulations that will require cosmetic manufacturers to disclose specific fragrance allergens directly on product labels, marking a shift from current practices that allow fragrance ingredients to be listed collectively under "parfum" or "fragrance."

The new requirements, published in the Canada Gazette, Part II in April 2024 as SOR/2024-63, will take effect in phased stages beginning April 12, 2026, bringing Canada into closer alignment with European Union cosmetics regulations.

Key Deadlines for Compliance

The regulations establish a three-phase implementation timeline:

• April 12, 2026 – Initial Phase: 24 Core Allergens

All cosmetic products (new and existing) must disclose 24 specific fragrance allergens when present above threshold concentrations.

• August 1, 2026 – Expansion Phase: 81 Allergens for New Products

Newly introduced cosmetics must disclose the full list of 81 fragrance allergens matching the EU's expanded requirements.

• August 1, 2028 – Full Compliance: All Products Covered

All cosmetics on the Canadian market must disclose the complete list of 81 fragrance allergens, where applicable.

Threshold Requirements Trigger Disclosure

The new regulations mandate disclosure based on product type:

• Rinse-off products ≥ 0.01% (shampoos, body washes, cleansers)
• Leave-on products ≥ 0.001% (moisturizers, serums, perfumes)

The 24 allergens required from April 2026 include commonly used fragrance ingredients:

• Amyl cinnamal,
• Amylcinnamyl alcohol,
• Anisyl alcohol,
• Benzyl alcohol,
• Benzyl benzoate,
• Benzyl cinnamate,
• Benzyl salicylate,
• Cinnamal,
• Cinnamyl alcohol,
• Citral,
• Citronellol,
• Coumarin,
• d-Limonene,
• Eugenol,
• Farnesol,
• Geraniol,
• Hexyl cinnamaldehyde,
• Hydroxycitronellal,
• Hydroxymethylpentyl-cyclohexenecarboxaldehyde (Lyral),
• Isoeugenol,
• Lilial (Butylphenyl methylpropional),
• Linalool,
• Methyl heptine carbonate, and
• 3-Methyl-4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-3-buten-2-one (Methyl ionone).

Labeling Changes Impact Ingredients List

The qualifying allergens must appear after "Fragrance (Parfum)" in descending order of concentration, alongside other ingredients in the full list. The following is an example.

BEFORE April 12, 2026 (Current Practice):
Ingredients: Water, Glycerin, ..., Fragrance (Parfum), ...

AFTER April 12, 2026 (Required):
Ingredients: Water, Glycerin, ..., Fragrance (Parfum), Linalool, Citronellol, ...

Canada's bilingual labeling requirements continue to apply. Where the INCI name does not differ between English and French, one listing is sufficient.

Cosmetic Notification Form (CNF) Requirements Updated

The CNF must be filed with Health Canada within 10 days of the first sale. Starting April 12, 2026, if a cosmetic formula contains any of the 24 qualifying fragrance allergens above the threshold, they must be disclosed individually in the Cosmetic Notification Form (CNF) ingredient list. These allergens can no longer be grouped under "fragrance" in the notification. 

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

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