If your only reference point for the Canadian market is a Cosmetic Notification Form you filed a few years ago, that form may no longer reflect what Health Canada expects.
Between October 2024 and April 2026 the cosmetic notification framework was rebuilt in stages. New definitions in the Cosmetic Regulations, a mandatory Canadian address, a finer set of concentration range codes, a new fragrance allergen field, and a fresh set of grounds on which a cosmetic simply cannot be sold.
For UK and EU brands, one detail makes this more complex: Canada has tied its fragrance allergen requirements directly to Annex III of the EU Cosmetic Products Regulation. Your European allergen work now does double duty but only if the Canadian notification is updated to match.
Key takeaways
- The cosmetic notification form must be submitted within 10 days after a cosmetic is first sold in Canada, under section 30 of the Cosmetic Regulations. There is no fee and no approval.
- Since 5 March 2025 the form requires a Canadian address for the manufacturer or the importer in section 4.
- Concentration range codes have been expanded from 7 to 13, giving Health Canada a much more granular picture of your formulation.
- From 12 April 2026, fragrance allergens above threshold must be disclosed individually on the label and in the CNF. They can no longer sit inside “parfum”.
- Since April 2026, giving the concentration of most fragrance allergens on the CNF is optional, unless the allergen carries a concentration-related Hotlist condition.
What the Health Canada cosmetic notification actually is
The Cosmetic Notification Form is the mechanism by which Health Canada is told that a cosmetic is on the Canadian market and what is in it.
Three points about the Health Canada cosmetic notification are worth stating plainly, because they are the source of most misunderstandings:
- Health Canada’s Industry Guide for the labelling of cosmetics is explicit that submitting a CNF does not constitute approval for sale, agreement that the product is classified as a cosmetic, or confirmation that it complies with legislative requirements. The Cosmetic Number issued afterwards is a record-keeping identifier.
- Any change to the primary product brand and name, to contact information, or to the formula requires an amendment within 10 days. Ceasing sale requires a discontinuation notification.
- Under subsection 15.3(1) of the Cosmetic Regulations, a cosmetic cannot be sold if the notification requirements have not been met after the 10-day period following first sale. Under subsection 15.3(2), the same applies if a revised notification is not provided within 10 days after the information becomes inaccurate.
Change 1: who is the “manufacturer”, and the Canadian address requirement
SOR/2024-63 rewrote the definition of “manufacturer” in subsection 2(1) of the Cosmetic Regulations. It now means either a person in Canada who sells the cosmetic under their own name or trademark, or a person in Canada authorised to act on behalf of a person outside Canada who sells under that other person’s name or mark.
Notably, Health Canada’s cosmetic notification guidance refers to the person in Canada authorised to act on behalf of the brand owner as the “responsible person”, adopting terminology from the EU cosmetics framework. Where a responsible person has not been designated, the importer is considered the manufacturer for the purposes of the notification.
The Guide for Cosmetic Notifications states that, as of 5 March 2025, the form requires a Canadian address for the manufacturer or the importer in section 4. For a UK or EU brand with no Canadian entity, a person in Canada must be authorised to act on your behalf, and their address goes on the cosmetic notification.
Change 2: contact point on labels
In 2024, the Canada Gazette released an amendment to the Canadian Cosmetics Regulations under the Food and Drugs Act. This update introduces several key changes to the regulatory framework for cosmetics in Canada, including the appointment of a Canada-based Responsible Person and new labelling requirements.
One notable change is the amendment to paragraph 20(a) of the Regulations, which requires the inner label of a cosmetic product to include one or more forms of digital contact information.
This measure aims at modernising how consumers access support and information about cosmetic products, ensuring they have a reliable way to ask questions or express concerns.
Change 3: fragrance allergens can no longer hide inside “parfum”
This is the change with the widest reach, and it is the one most likely to require reformulation, artwork changes and a portfolio-wide review of your Canadian cosmetic notification filings.
The thresholds
A fragrance allergen must be disclosed within the ingredient list, outside the term “parfum”, when present above 0.01% in rinse-off products or above 0.001% in leave-on products. The obligation applies regardless of the substance’s function in the product and applies even where the allergen arrives as a constituent of a botanical extract or essential oil. Health Canada’s own example: if a product contains Melissa Officinalis Extract and Geraniol within it exceeds the threshold, both must be declared.
The distinction between “leave-on product” and “rinse-off product” is now defined in subsection 2(1) of the Cosmetic Regulations, and the CNF requires you to state which your product is.
The timeline
| Date | Who is affected | What must be disclosed |
| 12 April 2026 | New and existing cosmetics | The 24 fragrance allergens in List 1 of Appendix 1 to the Industry Guide, plus the List 2 entries marked with an asterisk |
| 1 August 2026 | New cosmetics | The full expanded List 2 — 81 entries |
| 1 August 2028 | Existing products | The full expanded List 2 — 81 entries |
The legal mechanism matters here. The Cosmetic Regulations define a fragrance allergen by reference to the European Restricted Substances List, Annex III of Regulation (EC) No 1223/2009, as amended from time to time. This is an ambulatory incorporation by reference: when the EU amends Annex III, the Canadian obligation moves with it. The expansion from 24 to 81 entries follows the European Commission’s July 2023 amendment.
Grouped allergens
Several List 2 entries cover multiple substances and must be declared under a prescribed group name, for example “Rose Flower Oil/Extract”, “Lavandula Oil/Extract” or “Citral”. Disclosure is triggered when the sum of the concentrations of the substances within the grouped entry exceeds the threshold. Listing the individual substances as additional information is permitted but not required.
Change 5: the April 2026 flexibility on allergen concentrations
Industry raised a legitimate objection to the original approach: requiring the concentration of every fragrance allergen on the cosmetic notification form effectively meant handing over fragrance house compositions that are supplied under confidentiality.
Health Canada revised both the CNF and the Guide for Cosmetic Notifications in April 2026 in response. The position now is:
- The presence of a fragrance allergen above the disclosure threshold must still be reported: one allergen per ingredient line, with the “Fragrance allergen present above the disclosure threshold” checkbox selected.
- Concentration information for those allergens is no longer mandatory on the form.
- The exception is material: where a concentration-related Hotlist condition attaches to the fragrance allergen, the exact concentration or range code remains a mandatory field for processing.
- Health Canada continues to encourage voluntary disclosure of concentration or range in all cases, and voluntary disclosure speeds processing.
Last change: sharper enforcement hooks
SOR/2024-63 strengthened Health Canada’s oversight of cosmetics, and the notification pages now spell the consequences out. A cosmetic cannot be sold where the information required under subsection 30(2) has not been submitted, where a revised notification has not been received within 10 days of the information becoming inaccurate, or where information requested by Health Canada in relation to a notification was not provided within 10 days.
Health Canada may also request evidence of safety, request labels, or require relabelling, reformulation, removal from sale or recall. Failure to notify may result in a product being denied entry into Canada.
What this means for your business:
- Audit your existing Canadian portfolio. Every notified product with fragrance, flavour, botanical extracts or essential oils needs an allergen assessment against Lists 1 and 2. Essential oils are the usual source of surprises: lavender brings linalool, citrus oils bring limonene, lemongrass brings citral.
- Go back to your fragrance suppliers now. You need allergen declarations against the expanded EU Annex III list, in a format you can use for both the label and the cosmetic notification. If you have already done this work for the EU’s own deadlines, most of it transfers.
- Confirm your Canadian address is in place and accurate. If you have no Canadian entity, appoint someone in Canada authorised to act on your behalf before your next filing.
- Rebuild your artwork, bilingually. Fragrance allergens sit in the ingredient list after the ingredients above 1%, and the required order is: ingredients in descending concentration, then fragrance allergens, then parfum, then aroma, then colouring agents.
- File amendments, do not start over. Where a formula or label disclosure changes, submit an amendment with the Cosmetic Number. Keep the “.hcxs” file from each submission, without it you re-key the entire notification by hand.
- Check Hotlist conditions for each allergen. This determines whether concentration reporting is optional or mandatory on your form.
The EU angle
For a business already compliant in Europe, Canada has become markedly easier to reach. The allergen substance list is now the same list, because Canada incorporates EU Annex III by reference. What does not transfer is everything around it: bilingual English and French labelling, INCI naming rules specific to the Schedule of the Cosmetic Regulations, the Canadian contact and address requirements, the Cosmetic Ingredient Hotlist, and the notification itself.
An EU Product Information File and a CPNP notification do not satisfy any Canadian obligation. The Canadian cosmetic notification is a separate filing with its own data set and its own deadlines.
Frequently asked questions
Does the cosmetic notification form have to be filed before first sale?
No. The obligation is to notify within 10 days after first sale. In practice, notifying before or at launch is the safer approach, because the prohibition on sale in subsection 15.3(1) bites once that 10-day window closes on an incomplete notification.
Do I need a separate CNF for every shade?
Not necessarily. A single notification may cover multiple products where the same name or trademark applies to all of them, the base formulation is identical apart from slight variations in colouring, , and all other details, form, function, manufacturer, are the same. Different container sizes of the same product do not need separate filings.
Is there a fee for a Health Canada cosmetic notification?
No. There is no fee associated with the cosmetic notification process.
We list “parfum” on our EU label. Is that still acceptable in Canada?
Only for fragrance ingredients that are not fragrance allergens above the disclosure threshold. From 12 April 2026, qualifying allergens must appear individually in the ingredient list outside the term “parfum”, and correspondingly in section 5 of the cosmetic notification form.
What happens if we reformulate after notifying?
Submit an amendment within 10 days of the change, using the Cosmetic Number where you have one. Changes to the product brand and name, contact information, or the ingredient list all require an amendment.
How Obelis supports your Canadian filings
Obelis has supported manufacturers in the international market, acting as EU Responsible Person, Canadian Responsible Person , UK Responsible Person, and advising on compliance across the EU, UK, US, Switzerland, Canada and beyond. Our regulatory teams work daily with the same allergen data sets that Canada now relies on through its incorporation of EU Annex III.
If you are reviewing a Canadian portfolio against the fragrance allergen deadlines, working out who can hold your Canadian address, or aligning EU, UK and Canadian ingredient disclosures across one set of artwork, our consultants can help you scope the work and get the filings right the first time.
Contact Obelis for compliance services for cosmetics in Canada today.
Sources
- Health Canada, Notification of Cosmetics: Guide for Cosmetic Notifications (modified 2 April 2026): https://www.canada.ca/en/health-canada/services/consumer-product-safety/cosmetics/notification-cosmetics/guide.html
- Health Canada, Notification of Cosmetics — overview (obligations, prohibitions on sale under subsections 15.3(1) and 15.3(2), and paragraph 31(1)(a)): https://www.canada.ca/en/health-canada/services/consumer-product-safety/cosmetics/notification-cosmetics.html
- Health Canada, Notification of Cosmetics: Common issues when submitting a notification (Appendix 2), including fragrance allergen entry and the optional concentration policy: https://www.canada.ca/en/health-canada/services/consumer-product-safety/cosmetics/notification-cosmetics/common-issues-submitting.html
- Health Canada, Industry Guide for the labelling of cosmetics (modified 24 April 2026), in particular sections 8.3.8, 8.3.8.1 and Appendix 1 (Lists 1 and 2 of fragrance allergens): https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/industry-professionals/labelling-cosmetics.html
- Canada Gazette, Part II, Volume 158, Number 9: Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (SOR/2024-63), 24 April 2024: https://gazette.gc.ca/rp-pr/p2/2024/2024-04-24/html/sor-dors63-eng.html
- Cosmetic Regulations (C.R.C., c. 869), Justice Laws Website — in particular sections 2, 15.3, 21.4, 30 and 31: https://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._869/
- Food and Drugs Act (R.S.C., 1985, c. F-27), Justice Laws Website — in particular section 16: https://laws-lois.justice.gc.ca/eng/acts/f-27/
- Health Canada, Cosmetic Ingredient Hotlist: prohibited and restricted ingredients: https://www.canada.ca/en/health-canada/services/consumer-product-safety/cosmetics/cosmetic-ingredient-hotlist-prohibited-restricted-ingredients.html
- Health Canada, online Cosmetic Notification Form: https://healthycanadians.gc.ca/apps/radar/CPS-SPC-0007.08.html
- Regulation (EC) No 1223/2009 on cosmetic products, consolidated text of 24 April 2024 (Annex III, the European Restricted Substances List incorporated by reference into the Cosmetic Regulations): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02009R1223-20240424