Health Canada’s new fragrance allergen disclosure rules took effect April 12, 2026. Here’s what changed for your CNF filing and product labels — and what to do now.
If your company sells cosmetics in Canada, a significant regulatory change took effect on April 12, 2026 — and many brands have yet to update their Cosmetic Notification Form (CNF) filings or product labels to reflect it.
Here’s what changed, what it means for your products, and what steps to take now.
What Changed on April 12, 2026
Health Canada’s updated Cosmetic Regulations now require fragrance allergens to be individually disclosed on both cosmetic product labels and in the Cosmetic Notification Form. Previously, companies could list all fragrance ingredients collectively under the term “fragrance” or “parfum.” That option is no longer available for allergens above specified concentration thresholds.
The new requirements apply to:
- Rinse-off products — fragrance allergens present at concentrations above 0.01%
- Leave-on products — fragrance allergens present at concentrations above 0.001%
Starting April 12, 2026, 24 specific fragrance allergens must be individually named on your label and in your CNF filing. Beginning August 1, 2026, this expands to 81 allergens for new products. Existing products have until August 1, 2028 to comply with the expanded allergen list.
This Is Not Just a Label Change
Many companies have focused on updating product packaging — but the CNF filing itself must also be updated. Fragrance allergens can no longer be grouped under a collective “fragrance” entry in the notification. Each qualifying allergen must be individually disclosed in the ingredient list section of your CNF.
If you have existing CNF filings that do not reflect these changes, those filings are now inaccurate. Under the Cosmetic Regulations, you are required to submit a revised notification within 10 days of a filing becoming inaccurate.
What Else Is Changing in 2026
Beyond the fragrance allergen requirements, Health Canada has been updating its Cosmetic Ingredient Hotlist — the list of ingredients that are restricted or prohibited in cosmetics sold in Canada. A consultation period that closed in early 2026 proposed adding several new substances to the restricted category, including Basic Violet 4 due to potential carcinogenicity concerns.
Companies should review their full ingredient lists against the current Hotlist and factor any proposed changes into their formulation planning now.
The CNF Filing Process Has Also Changed
Since 2025, Health Canada has migrated cosmetic notifications to an updated Cosmetic Notification System (CNS) portal. The new platform includes improved data validation, better error-checking for INCI names, and updated guidance integrated into the filing workflow. If your team filed CNFs before 2025, the interface looks different and the field requirements have changed — including the requirement, effective March 5, 2025, that a Canadian address for the manufacturer or importer be included in Section 4 of the form.
What To Do Now
- Review your ingredient lists for any fragrance allergens above the applicable thresholds
- Update your product labels to individually disclose qualifying allergens
- Submit revised CNF filings for any affected products
- Check your ingredient lists against the current Cosmetic Ingredient Hotlist
- Plan ahead for the August 2026 expanded allergen requirements for new products
How Arora 297 Can Help
Our team has been filing cosmetic notifications with Health Canada for over 20 years. We help cosmetic brands, importers, and manufacturers review their CNF filings, identify compliance gaps, and submit accurate, complete notifications — including under the updated 2025–2026 requirements.
If you’re unsure whether your current CNF filings and labels meet Health Canada’s new standards, a compliance review is the right first step.
Book a free assessment at arora297consultancy.com or call +1-519-498-5957.
