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Fragrance allergens are among the common causes of cosmetic-related contact dermatitis, prompting regulators worldwide to strengthen transparency requirements. Recent updates in the European Union (EU) and Canada mark a significant shift toward consumer protection and Global Regulatory harmonization.
EU: Expanded Allergens List and Key Deadlines
The EU’s Commission Regulation (EU) 2023/1545 introduced a major expansion in fragrance allergen disclosure. The number of allergens requiring individual labeling has increased from 24 to over 80+ substances, reflecting updated scientific assessments by the Scientific Committee on Consumer Safety (SCCS).
Two critical compliance deadlines define the transition:
- July 31, 2026 – All new cosmetic products placed on the EU market must comply with the updated allergen labeling requirements.
- July 31, 2028 – Full compliance for all products already on the market.
While fragrance allergens were already subject to disclosure requirements, this regulation significantly expands the list of substances that must be individually declared rather than covered under ‘parfum’, enabling consumers with sensitivities to make informed choices. It also drives manufacturers to reassess formulations, supply chains, and labeling strategies.
Canada: Phased Disclosure Deadlines
Canada has closely aligned its framework with the EU through amendments to its Cosmetic Regulations (SOR/2024-63). The rollout follows a phased approach:
- April 12, 2026 – Mandatory disclosure of 24 fragrance allergens above threshold for all products.
- August 1, 2026 – Mandatory disclosure of allergens (≈81 allergens) above threshold is required for new products entering the market.
- August 1, 2028 – Mandatory disclosure of allergens (≈81 allergens) above threshold is required for all existing products.
Thresholds triggering disclosure remain consistent with the EU: 0.001% for leave-on products and 0.01% for rinse-off products.
This alignment reduces complexity for global brands while improving consumer safety through clearer labeling.
Canada’s Updated CNF Form: What’s Changed?
The Cosmetic Notification Form (CNF), a mandatory post-market notification tool in Canada, has undergone significant updates alongside allergen regulations.
Key changes include:
- Mandatory allergen disclosure in CNF filings: Fragrance allergens must be individually listed rather than grouped under “fragrance” when present above the threshold. Stricter update requirements: Companies must revise CNF submissions within 10 days if product information becomes inaccurate.
- Reduced burden on concentration reporting: Health Canada now considers allergen concentration reporting optional for most substances, except those on the Cosmetic Ingredient Hotlist.
These updates balance transparency with industry practicality, addressing concerns about proprietary fragrance compositions while maintaining consumer safety.
Final Thoughts
The evolving landscape of fragrance allergens signals a broader move toward global regulatory convergence. For cosmetic companies, this is not merely a labeling or an HC CNF update; it demands supplier collaboration and robust compliance systems. Organizations that act early will not only meet deadlines but also strengthen consumer trust in an increasingly transparency-driven market.
Consult Freyr for expert regulatory guidance on fragrance allergens reporting.
