On 5 March 2025, Health Canada updated its Cosmetic Notification Form to officially include the requirement to have a Canadian-based representative to sell cosmetics in Canada.
While this requirement has been in place since October 2024, it is now being actively enforced through this regulatory update.
Amendment to the Cosmetics Regulations
As of 12 April 2024, the definition of “manufacturer” under the Canadian Cosmetics Regulations has been expanded to include:
- Any person in Canada who sells a cosmetic under their own name, trademark, trade name, or other identifying mark they own or control.
- Any person in Canada authorised to act on behalf of a foreign entity that sells a cosmetic under its own name or brand.
Implications for Foreign Brands Selling in Canada
Foreign brand owners are now required to appoint a Canadian-based representative to:
- Ensure compliance with ingredient restrictions.
- Confirm proper product classification and marketing claims.
- Verify compliance with labeling requirements.
- Maintain evidence of cosmetic safety.
- Submit a Cosmetic Notification Form.
- Communicate effectively with Health Canada on regulatory matters.
Failure to meet these obligations can result in regulatory actions, delays, or product removal from the Canadian market.
How Obelis Supports Cosmetic Brands Entering Canada
Navigating Canadian cosmetic regulations can be challenging for foreign brands. Obelis offers expert support to ensure compliance, including:
- Acting as your Canadian-based representative.
- Submitting Cosmetic Notification Forms on your behalf.
- Advising on ingredient, labeling, and marketing compliance.
- Providing ongoing regulatory updates and guidance.
With Obelis as your partner, you can enter the Canadian market confidently and maintain compliance with Health Canada’s evolving requirements.
FAQ
- What is the new Canadian requirement for cosmetic brands?
As of 5 March 2025, Health Canada requires all foreign cosmetic brands to appoint a Canadian-based representative to sell products in Canada. This representative is responsible for ensuring compliance with Canadian cosmetic regulations.
- Has this requirement been in place before?
Yes. The requirement has existed since October 2024, but Health Canada is now actively enforcing it following updates to the Cosmetic Notification Form.
- How has the definition of “manufacturer” changed in Canada?
Under the Cosmetics Regulations (amended 12 April 2024), “manufacturer” now includes:
- Any person in Canada selling a cosmetic under their own brand, trademark, or trade name
- Any person in Canada authorized to act on behalf of a foreign entity selling a cosmetic under its own name or brand
- Who must appoint a Canadian-based representative?
Foreign cosmetic brand owners selling products in Canada must appoint a Canadian-based representative to assume responsibility for regulatory compliance.
- What are the responsibilities of a Canadian-based representative?
The representative must ensure:
- Compliance with ingredient restrictions
- Correct product classification and marketing claims
- Compliance with labeling requirements
- Availability of evidence of cosmetic safety
- Submission of the Cosmetic Notification Form
- Effective communication with Health Canada
- How can Obelis help foreign cosmetic brands in Canada?
Obelis acts as your Canadian-based representative, providing regulatory support to ensure:
- Full compliance with Canadian cosmetic regulations
- Smooth submission of Cosmetic Notification Forms
- Guidance on ingredient, labeling, and safety compliance
- How do I get started with Obelis for Canadian market entry?
Contact our team to learn how Obelis can support your cosmetic brand in Canada and ensure compliance with Health Canada’s regulatory requirements.
Chiara Lai
Obelis Regulatory & Intelligence Department
References:
Canada Gazette. (2024). SOR/2024-63: Regulations Amending Certain Regulations Concerning Drug and Medical Device Safety. Retrieved on 12 February 2025.
Canada Gazette. (2024). Official Publications of the Government of Canada. Retrieved on 12 February 2025.
Justice Laws Website. (2024). Food and Drugs Act – Cosmetic Regulations (C.R.C., c. 869). Retrieved on 12 February 2025.
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