On March 6, Health Canada published an official notice regarding fragrance allergen concentration reporting on the Cosmetic Notification Form (CNF). As you may recall this ‘win’ was first announced at CA’s Fall Regulatory Workshop last year by the Consumer & Hazardous Products Safety Directorate.
Reporting the concentration of fragrance allergens on CNF is now optional. While Health Canada is not formally amending the Cosmetic Regulations, they are introducing policy flexibility regarding these disclosures.
The “Wins” at a Glance
- Concentration Reporting is Now Optional: reporting the specific concentration or range code on the CNF will now be optional rather than mandatory for fragrance allergens.
- The Hotlist Exception: If a fragrance allergen is also restricted on the Cosmetic Ingredient Hotlist (e.g., Eucalyptus, Camphor, or Methyl Salicylate), providing the concentration or range code remains mandatory.
Operational Updates
- CNF Updates
The current CNF still requires a concentration entry. However, Health Canada is revising the form to allow allergens to be entered without this data. This update is expected for Summer 2026.
- Interim Strategy: If you do not have the concentration data, you can wait to file your amended CNF until the new form is released.
- Known Concentrations: If you do have the data, Health Canada encourages its inclusion however this is not mandatory. Ensure you check the “Fragrance Allergen” box so the concentration does not count toward the total formula concentration.
- Revised Guidance
An updated Cosmetic Notification Guide will be released concurrently with the new form.
If you have any questions or concerns please reach out to regulatory@cosmeticsalliance.ca.
