Regulatory Update: Canadian cosmetics market
March 25, 2026
Staying Compliant: Navigating Canada’s New Cosmetic and Fragrance Allergen Regulations
As the global landscape for cosmetic safety continues to evolve, Health Canada has recently introduced significant updates to its cosmetic regulations. These changes, which largely mirror the European Union’s stringent standards, represent a major shift in how cosmetic products must be represented and labelled in the Canadian market. For brands operating in or exporting to Canada, understanding these new requirements is essential to ensuring uninterrupted market access and consumer trust.
These updated regulations can seem daunting, if you have any questions or concerns our Technical team are ready to help. We are experts in cosmetics regulations whichever market you are active in, and we’re keen to help anyone who needs it.
The Introduction of the Canadian-Based “Responsible Person”
One of the most critical administrative changes is the formal requirement for a Canadian-based representative, often referred to in industry circles as a “Responsible Person” (RP). As of March 2025, all cosmetic notifications submitted to Health Canada must include a contact person located within Canada. The RP serves as the primary liaison between the brand and Health Canada, ensuring that safety information and regulatory inquiries can be addressed promptly within Canada. As per the EU and UK regulations, the RP contact details are printed on the packaging, and in the event of any adverse events, the Competent Authority (such as a medical doctor) can easily locate and contact the RP for more information.
Cosmetic Product Safety Report
A Cosmetic Product Safety Report (CPSR) is a detailed document for each cosmetic product being sold on the market. It’s a document that proves your product is safe for consumers to use, and includes:
- Information about the product’s ingredients
- How it’s manufactured
- Safety testing
- Potential hazards or warnings that should accompany the product.
Health Canada doesn’t require you to submit the CPSR directly, but you need to have one on file and be able to provide it if the regulator asks for it. Think of it as evidence that you’ve done your due diligence to ensure the product is safe.
Under the new regulations the CPSRs need to be updated to reflect the new allergen disclosure requirements. If your CPSR lists fragrance allergens under the old system (just “fragrance”), it now needs to be updated to list the specific allergens individually.
CPSRs are available for Darent Wax customers at no extra charge.
Enhanced Fragrance Allergen Disclosure
In a move to increase transparency for consumers with sensitive skin and allergies, Health Canada is mandating the disclosure of specific fragrance allergens within the International Nomenclature for Cosmetic Ingredients (INCI) list. Previously, these could often be grouped under the generic terms “fragrance” or “parfum.” Following the EU’s lead, Canada will now require the individual naming of allergens when they exceed specific concentration thresholds.
| Product Type | Concentration Threshold for Disclosure |
| Rinse-off products (e.g., shampoos, soaps) | > 0.01% |
| Leave-on products (e.g., creams, lotions) | > 0.001% |
Note: Depilatory waxes are considered ‘rinse-off’ cosmetics.
Critical Deadlines for Compliance
The transition to these new standards is structured to allow the industry time to adjust formulations and packaging. However, the deadlines are firm, and brands must begin their preparations immediately to avoid non-compliance.
| Requirement Type | Deadline for New Products | Deadline for Existing Products |
| Initial 24 Allergens (List 1) | April 12, 2026 | April 11, 2027 (End of Grace Period) |
| Expanded Allergen List (List 2) | August 1, 2026 | August 1, 2028 |
Note: For products already on the market, the “compliance-promotion” approach provides a 12-month grace period for the initial allergen list, making April 11, 2027, the final date for full compliance for existing stock.
Implications for Bulk Packaging and Documentation
A significant area of focus under the updated regulations is the requirement for comprehensive labelling on all levels of packaging. While bulk boxes have historically seen less rigorous ingredient listing, the stricter enforcement of INCI disclosure means that even secondary and bulk packaging may now require full ingredient transparency.
Furthermore, brands should proactively review their Cosmetic Product Safety Reports (CPSRs) and INCI lists. Ensuring that these documents are updated to reflect the presence of newly regulated allergens is not just a regulatory necessity but a vital step in maintaining consumer safety and brand integrity.
Next Steps for Partners
If your brand is based in Canada or has significant distribution there, now is the time to audit your product portfolio. We can help you:
- Verify the presence of allergens in your current fragrances.
- Update your INCI labelling for both retail and bulk packaging.
- Ensure your Canadian-based representative information is current in the Health Canada database.
Staying ahead of these regulations ensures that your products remain a trusted choice for Canadian consumers.
We make compliance easy. Let us help you navigate these changes.
