Canada fragrance allergen labelling for US cosmetics sellers (2026–2028)

Dates

• April 12, 2024: SOR/2024-63 registered (P.C. 2024-316)

  “SOR/2024-63 April 12, 2024”Source: gazette.gc.ca

• October 9, 2024: All of SOR/2024-63 except section 6 in force (180th day after registration; date computed from 2024-04-12): small-package website ingredient option, notification changes, new definitions

  “14 (1) These Regulations, except section 6, come into force on the 180th day after the day on which they are registered.”Source: gazette.gc.ca

• March 5, 2025: Cosmetic Notification Form requires a Canadian address for the manufacturer or importer in section 4

  “Important: As of March 5, 2025, the form requires that a Canadian address for the manufacturer or the importer be provided in section 4.”Source: canada.ca

• April 12, 2026: Section 6 (fragrance allergen disclosure) in force on the second anniversary of registration

  “(2) Section 6 comes into force on the second anniversary of the day on which these Regulations are registered.”Source: gazette.gc.ca

• April 12, 2026: New and existing cosmetics must disclose the 24 List 1 allergens (asterisked in List 2) above 0.01% rinse-off / 0.001% leave-on

  “As of April 12, 2026, new and existing cosmetics have to disclose 24 fragrance allergens (see List 1 in Appendix 1) within the list of ingredients, when present at concentration greater than 0.01% in rinse-off products and 0.001% in leave-on products.”Source: canada.ca

• April 12, 2026: Fragrance allergens above the thresholds must be shown on the Cosmetic Notification Form

  “As of April 12, 2026, the presence of any fragrance allergens must be provided on the cosmetic notification form when present in concentrations greater than 0.01% in rinse-off products, and greater than 0.001% in leave-on products.”Source: canada.ca

• July 31, 2026: EU (context): products not meeting the 2023/1545 labelling restrictions may be placed on the EU market until 31 July 2026 and made available until 31 July 2028; Canada uses August 1, 2026 / August 1, 2028

  “Cosmetic products containing that substance that do not comply with the restrictions may be placed on the Union market until 31 July 2026 and made available on the Union market until 31 July 2028”Source: eur-lex.europa.eu

• August 1, 2026: New cosmetics must disclose the full List 2 (81 entries)

  “As of August 1, 2026, new cosmetics must disclose fragrance allergens from List 2 (see Appendix 1), when present at concentration greater than 0.01% in rinse-off products and 0.001% in leave-on products.”Source: canada.ca

• August 1, 2026: RIAS: "existing products" means products on the market before August 1, 2026

  “Requirements for existing products (products on the market before August 1, 2026) will be introduced in two stages over approximately four years”Source: gazette.gc.ca

• August 1, 2028: Existing products must disclose the full List 2

  “As of August 1, 2028, existing products must disclose fragrance allergens from List 2 (see Appendix 1), when present at a concentration greater than 0.01% in rinse-off products and 0.001% in leave-on products.”Source: canada.ca

• August 1, 2028: RIAS confirms the August 1, 2028 date for existing products (expanded EC list)

  “disclosure of the presence of any of the fragrance allergens from the EC expanded list on cosmetic labels will be required as of August 1, 2028”Source: gazette.gc.ca

Sources conflict: A trade article (Personal Care Insights) says the additional allergens apply to existing products "by April 11, 2027". Health Canada's labelling guide and the SOR/2024-63 RIAS both say existing products must disclose the List 2 allergens as of August 1, 2028. Trade press (ChemLinked, Complife, Personal Care Insights) also reports that a Health Canada stakeholder email of 2026-03-06 set a "compliance promotion" phase from 2026-04-12 to 2027-04-11 with standard risk-based enforcement from 2027-04-12; that may be the source of the 2027 figure. That stakeholder notice was not found on canada.ca and is unverified. (personalcareinsights.com). We use the government's dates.

Thresholds

• rinse-off: above 0.01%

  “(a) in the case of a rinse-off product, the concentration of the fragrance allergen in the cosmetic is greater than 0.01%”Source: gazette.gc.ca

• leave-on: above 0.001%

  “(b) in the case of a leave-on product, the concentration of the fragrance allergen in the cosmetic is greater than 0.001%”Source: gazette.gc.ca

• grouped entries (sum)

  “The requirement for the mandatory disclosure of the group allergen is when the sum of the concentrations of the substances within the grouped entry exceeds 0.001% in leave-on products or 0.01% in rinse-off products.”Source: canada.ca

Selling online from the US

Health Canada says Canada's product safety laws apply to anyone, wherever they are located, who sells cosmetics online to consumers in Canada. It recommends that online listings show the ingredient list, label, instructions and warnings in English and French.

“No matter where you are located in the world, if you operate an online marketplace or sell consumer products or cosmetics to Canadian consumers online, be aware of Canadian product safety laws and regulations and comply with them.”Source: canada.ca

Regulation: SOR/2024-63 Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (Canada Gazette, Part II, Vol. 158, No. 9, 2024-04-24)

Allergen calculator

Enter the allergen percentages from your fragrance supplier's allergen declaration (often on the IFRA certificate or a separate allergen statement) and how much fragrance is in your product. The calculator multiplies the two and compares the result with the threshold.

Use only your supplier's declared figures for the exact fragrance or essential oil you buy. This calculator never uses "typical" essential-oil compositions: they vary by batch, origin and distillation, and a guess is not a declaration.

The allergen list

Names and lists from Health Canada's labelling guide, Appendix 1; CAS numbers from Commission Regulation (EU) 2023/1545, Annex III.

Bilingual label checklist

• Product identity (common name or function, e.g. "body scrub") in English and French on the principal display panel of the outer label

  “On the outer label, the declaration of product identity must appear in both English and French on the principal display panel.”Source: canada.ca

• Net quantity in metric units, in English and French, on the principal display panel (metric symbols such as g or mL count as bilingual)

  “On the outer label, the declaration of net quantity must appear in both English and French on the principal display panel.”Source: canada.ca

• Numbers in the net quantity in bold type

  “The numerical part of the net quantity declaration must appear in boldface type.”Source: canada.ca

• Dealer name and principal place of business (address complete enough for postal delivery), in English or French

  “The identity and principal place of business may appear in English, French, or both official languages.”Source: canada.ca

• Imported product: a foreign dealer's name and address is allowed, or the Canadian dealer preceded by "imported by / importé par"

  “showing the identity and principal place of business of the Canadian dealer preceded by the words "imported by" ("importé par") or "imported for" ("importé pour")”Source: canada.ca

• Inner label: a contact (phone, email, website or postal address) for product questions; the contact should answer in both official languages

  “The contact should be able to provide a timely response to any questions in both official languages.”Source: canada.ca

• Full ingredient list on the outer label using INCI names

  “The list of ingredients must appear on the outer label of a cosmetic, or if the cosmetic has one label only, on that label.”Source: canada.ca

• INCI names do not need to be translated

  “The INCI names do not need to be provided on the label in both French and English according to subsection 18(a) of the Cosmetic Regulations.”Source: canada.ca

• Ingredient order: descending order, then fragrance allergens, then parfum, then aroma, then colours ("may contain / peut contenir")

  “Order of ingredients: [ingredients in descending order of concentration] + [fragrance allergen, if applicable] + [parfum/fragrance ingredients] + [aroma/flavour ingredients] + [± or "may contain/peut contenir" colouring agents].”Source: canada.ca

• Fragrance allergens above the threshold listed by name outside "parfum", even when they come from a botanical/essential oil

  “Fragrance allergens must be disclosed within the list of ingredients, outside of the term "parfum", when present above the specified concentration, noted above, regardless of their function in the product and even if it is part of a botanical extract.”Source: canada.ca

• Warnings, cautions and directions needed to avoid a hazard in English and French

  “This requirement can be satisfied through a combination of instructions for use, cautions, and symbols, in both English and French.”Source: canada.ca

• Required text at least 1.6 mm high (0.8 mm if the principal display surface is under 10 cm2)

  “must be in letters of not less than 1.6 mm in height. When the area of the principal display surface is less than 10 cm2, the information may be in letters of not less than 0.8 mm in height.”Source: canada.ca

• Small packages: ingredients on an attached tag/tape/card, or on a website if the label carries a bilingual statement with the web address

  “the list of ingredients can appear on a website, provided that there is a bilingual statement on the label advising consumers that the list of ingredients can be found on that website and includes the web address/url.”Source: canada.ca

• Unpackaged soap or bath bombs sold loose: all required label information on a leaflet that accompanies the product at point of sale

  “Examples of such products include bath bombs or soap (sold by weight or individually), and other bulk or loose products. All the information required on a cosmetic label by the CR must appear on this leaflet.”Source: canada.ca

Cosmetic Notification Form

Manufacturers and importers must notify Health Canada (Cosmetic Notification Form) within 10 days after first selling a cosmetic in Canada. As of March 5, 2025 the form requires a Canadian address for the manufacturer or the importer in section 4; under the amended Regulations a "manufacturer" can be a responsible person in Canada acting for a manufacturer without a Canadian address. From April 12, 2026 fragrance allergens above the thresholds must be flagged on the form. Health Canada's notification guide. We don't file notifications.

“Important: As of March 5, 2025, the form requires that a Canadian address for the manufacturer or the importer be provided in section 4.”Source: canada.ca

May not be a cosmetic in Canada