Source record
- Jurisdiction
- European Union, Canada
- Issuing authority
- European Commission and Health Canada
- Document status
- Final regulations and implementation guidance
- EU regulation adopted
- Source checked
- Canada initial allergen requirement
- EU placing-on-market transition ends
- Canada expanded list for new cosmetics
- EU making-available transition ends
- Canada expanded list for existing cosmetics
Original documents
A product sold in both the EU and Canada cannot rely on one fragrance-allergen deadline for both markets. The EU transition depends on placement and subsequent supply; Canada’s timetable distinguishes new and existing cosmetics and includes an initial 24-allergen requirement.
Compare the dates first, then work through the finished-product calculation and the label and notification documents for each market.
Compare the timetables first
| Market and requirement | Key dates |
|---|---|
| EU expanded labelling | Placing-on-the-market transition ended 31 July 2026; qualifying stock transition ends 31 July 2028 |
| Canada initial 24-allergen list | Required for new and existing cosmetics from 12 April 2026 |
| Canada expanded list: new cosmetics | Required from 1 August 2026 |
| Canada expanded list: existing cosmetics | Required from 1 August 2028 |
The Canadian disclosure dates apply where the concentration thresholds are exceeded. The later expanded-list transition does not postpone the initial 24-allergen requirement. Canada’s regulatory explanation treats existing products as those on the market before 1 August 2026.
The EU distinction concerns placement and subsequent making available; qualifying stock may continue to be made available during the remaining transition. Follow the relevant category and conditions for each destination, including the applicable EU Annex III entry.
Calculate in the finished product
The disclosure thresholds are greater than 0.001% in leave-on products and greater than 0.01% in rinse-off products. They concern the concentration in the cosmetic, not in a fragrance concentrate.
In a simplified hypothetical example, a formula contains 0.5% fragrance with 0.4% of a listed allergen:
0.5 × 0.4 ÷ 100 = 0.002% in the finished product.
That contribution exceeds the leave-on threshold. Add any other contributions before comparing the total. Health Canada specifies that disclosure can apply regardless of an ingredient’s function, including allergens contributed by botanical extracts.
For supplier declarations, check the grade, revision, concentration basis, and meaning of ranges or missing values. A spreadsheet that examines only the fragrance line can miss relevant inputs.
Check grouped entries and declaration names
The EU amendment changes some substance identities and grouping as well as adding allergens. Consult Annex III for the binding entry and conditions; CosIng is an information tool.
Health Canada requires the group name for grouped allergens when the summed concentration exceeds the relevant threshold. Keep the calculation and name selection together so the artwork reviewer can follow both.
Update artwork and Canadian notification information
Review the formula, required declarations, market, and transition category before approving the ingredient list. Then check the text in the actual artwork.
Canada’s notification guide also addresses relevant fragrance allergens on the Cosmetic Notification Form. Review notification information alongside the labelling timetable, including the initial requirement already in effect and the expanded list as applicable.
If customers ask why the ingredient list is longer, explain that disclosure helps sensitised people identify substances they need to avoid. Additional names do not by themselves establish that the formula changed or became unsafe.
