In March 2025, Health Canada released an updated version of its Guide for Cosmetic Notifications, outlining important revisions to the Cosmetic Notification Form (CNF). These changes are designed to enhance regulatory compliance, improve transparency, and boost consumer safety.
Here’s an overview of the key updates businesses need to know.
Important Updates in the Cosmetic Notification Process
1. Product Classification: Leave-on vs. Rinse-off
A major revision in the updated guide is the introduction of a mandatory field to specify whether a product is a leave-on or rinse-off cosmetic. Previously, this distinction wasn’t required. This classification is important because it allows Health Canada to apply the correct safety regulations based on how the product is used. For example, leave-on products like lotions or sunscreens may have stricter safety guidelines compared to rinse-off products such as shampoos or face cleansers. This change helps ensure products are properly categorized for better consumer protection.
2. Ingredient Concentration Range Codes
The updated CNF now allows businesses to report ingredient concentrations using standardized range codes or by specifying exact concentrations. This change simplifies the reporting process, enabling Health Canada to evaluate products more consistently. Additionally, it improves ingredient transparency, especially for substances that could pose risks at higher concentrations.
3. Canadian Entity Information Requirement
The updated CNF guidance now requires businesses to provide a Canadian address for the manufacturer or importer listed in section 4. This change ensures that Health Canada has a designated regulatory contact within Canada.
According to the revised regulations, a manufacturer is now defined as:
- A Canadian manufacturer that sells the cosmetic under their own name or a controlled trademark, trade name, or design.
- A responsible person in Canada acting on behalf of a manufacturer without a Canadian address.
- If no entity in Canada qualifies as the manufacturer, the importer or any individual who manufactures or processes the cosmetic in Canada is considered the manufacturer.
Furthermore, if an importer is identified in section 4, the contact details of the person who formulated or manufactured the cosmetic must also be provided under the “Formulator” or “Third-Party Manufacturer” contact type. If this individual is different from the listed manufacturer, their information must be included separately.
Lastly, businesses must also declare a “Label Contact” in section 4 of the CNF, which should correspond to the consumer-facing contact details found on the product label.
Effective March 5, 2025, providing a Canadian address for the manufacturer or importer in section 4 will be mandatory.
4. Fragrance Allergen Disclosure
A new rule mandates the disclosure of fragrance allergens on product labels if they exceed specific limits. The previous version of the CNF didn’t require this. This update is aimed at enhancing consumer safety by making allergen information more accessible. A transition period is in place, with full compliance expected by July 31, 2026, for new products and by July 31, 2028, for existing products.
Final Remarks
Health Canada’s updated Guide for Cosmetic Notifications introduces several important revisions to ensure greater product transparency and consumer protection. By following the updated requirements, such as specifying product classification, using ingredient range codes, and disclosing fragrance allergens, businesses can ensure compliance with Health Canada’s safety standards.
Regulatory Support
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