Health Canada’s Risk-Based Compliance and Enforcement Approach for Fragrance Allergen Disclosure Requirements

Posted Date: 18-March-2025

NHP Labelling Engagement – Update and Next Session

 

The provisions related to the disclosure of the first set of 24 fragrance allergens on cosmetic product labels (new or existing) were provided a two-year transition period. This means that the requirements to disclose these 24 fragrance allergens will come into force on April 12, 2026.

Cosmetic Alliance had been in several meeting with the Consumer & Hazardous Products Directorate (CHPSD) over several months advocating for a transition timeline similar to Europe for the 24 fragrance allergens. As result of these advocacy efforts, Cosmetics Alliance was able to secure one on one meetings between Health Canada and interested member companies to present their case for additional time to meet the April 12, 2026, timeline. Following these meetings Health Canada still expects industry to maintain best efforts to ensure that cosmetic products comply with the fragrance allergen disclosure requirements as of April 12, 2026.

In line with the Departmental risk-based compliance and enforcement policy framework, the following approach will be applied to the disclosure requirements for the first set of 24 fragrance allergens:

  • From April 12, 2026 to April 11, 2027, Health Canada will focus on compliance promotion with regulated parties; and
  • From April 12, 2027 onwards, compliance and enforcement will follow a risk-based approach as per standard Departmental and program guidance.
  • All other transition periods associated with the amendments to the Cosmetic Regulations published in Canada Gazette, II in April 2024 remain unchanged.

Should Health Canada receive reports of health or safety-related incidents or complaints once the labelling requirements for the initial list of 24 allergens are in force (from April 12, 2026), the Department will respond following its usual risk-based process.

If you have any questions or concerns please reach out to regulatory@cosmeticsalliance.ca.