Key Takeaways:
Health Canada has revised its regulatory approach to fragrance allergen reporting, easing certain administrative requirements for companies submitting cosmetic notifications while maintaining consumer labeling obligations. The update affects how fragrance allergens are reported through Canada’s Cosmetic Notification Forms (CNFs), which manufacturers and importers must submit when introducing cosmetic products to the Canadian market.
Under the revised approach, companies will no longer be required to report the exact concentration of most fragrance allergens in the CNF. The change is designed to reduce administrative burden on industries while maintaining regulatory oversight. Companies must still ensure that ingredients comply with the Health Canada Cosmetic Ingredient Hotlist, which lists substances that are prohibited or restricted in cosmetic products.
Importantly, the update does not alter consumer-facing labeling requirements. Cosmetic products sold in Canada must still disclose fragrance allergens on their ingredient lists when they exceed established thresholds: 0.001% in leave-on products and 0.01% in rinse-off products. These disclosure rules form part of Canada’s broader effort to align fragrance allergen transparency with international regulatory frameworks. The country is also introducing a phased list of allergens that must be individually declared on cosmetic labels, beginning with 24 substances and expected to expand to a larger group in subsequent stages.
For manufacturers, the revised reporting approach primarily simplifies the regulatory notification process. By removing the requirement to submit precise concentration data for most allergens, the policy reduces the amount of detailed formulation information companies must provide when filing a CNF, while still requiring that products remain compliant with safety restrictions and labelling obligations.
The update arrives as fragrance allergen transparency continues to gain attention globally, particularly in North America. In the United States, fragrance allergen disclosure rules are currently under development following the passage of the Modernization of Cosmetics Regulation Act (MoCRA) of 2022. Under MoCRA, the US Food and Drug Administration is required to propose a rule establishing fragrance allergen disclosure requirements for cosmetic labels. The FDA missed its first deadline for a proposed rule in 2024. The agency is expected to release a proposed rule in May 2026; the US currently does not have a federal requirement to list fragrance allergens.
While Canada has already implemented allergen labeling thresholds similar to those used in other jurisdictions, the United States has historically relied on the umbrella term “fragrance” in ingredient lists. The forthcoming FDA proposal may therefore represent a significant shift toward greater ingredient transparency.
Together, these developments are proof of a broader regulatory focus on fragrance allergens and cosmetic ingredient disclosure across North America. For brands operating internationally, evolving requirements in both Canada and the United States are likely to influence how fragrance ingredients are formulated, documented, and communicated to consumers.