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Cosmetic Testing Lab

Selling Cosmetics in Canada: Notification, Hotlist and Labels

December 9, 2023  ·  8 min read

Selling Cosmetics in Canada: Notification, Hotlist and Labels

Canada is an attractive export market for European brands, but the rules are not a copy of the EU system. If you plan to sell cosmetics in Canada, you will deal with Health Canada, a notification form, an ingredient list of prohibited and restricted substances, bilingual labels and a fragrance allergen rule that is being phased in. This guide shows each step and how much of your EU documentation you can reuse.

Contents
  1. The short answer
  2. Who regulates cosmetics in Canada?
  3. The Cosmetic Notification Form (CNF)
  4. Who files if you are based in Europe?
  5. The Cosmetic Ingredient Hotlist
  6. Bilingual labelling: English and French
  7. Fragrance allergen labelling
  8. Is your product a cosmetic at all?
  9. What your EU documents give you
  10. Canada launch checklist
  11. Common mistakes
  12. How Cosmetic Testing Lab helps
  13. Frequently asked questions
  14. Key takeaways

The short answer

To sell a cosmetic in Canada you must notify Health Canada with a Cosmetic Notification Form within 10 days of first sale, keep the formula within the limits of the Cosmetic Ingredient Hotlist, and label the product in English and French according to the Cosmetic Regulations. There is no pre-market approval and no requirement we found for an EU-style safety report, but you remain responsible for the safety of what you sell. Rules change, so confirm every point on the Health Canada pages below.

Who regulates cosmetics in Canada?

Health Canada regulates cosmetics under the Food and Drugs Act and the Cosmetic Regulations. In simple terms, the Act prohibits selling a cosmetic that may harm the user when used as intended, and the Regulations add requirements for notification and labelling. Health Canada does not approve products before sale. It checks the market, can ask for information and can have a product refused at the border or removed from sale.

Read also Selling Cosmetics in Japan: MAH, Notification and Labels

The Cosmetic Notification Form (CNF)

According to Health Canada’s guide, manufacturers and importers of a cosmetic sold in Canada must notify the department with the CNF within 10 days after the first sale in Canada. The same 10-day window applies when something changes and when you stop selling the product. Health Canada says that selling a cosmetic without the required notification, or after a required update is overdue, can lead to it being denied entry or removed from sale. Receiving a notification number is not an approval.

The form typically asks for:

  • a unique product name that matches the label;
  • function, form, area of application and whether the product is leave-on or rinse-off;
  • a complete ingredient list using INCI names, with concentrations or concentration ranges;
  • fragrance allergens above the disclosure thresholds;
  • contact details for the notifier, the manufacturer or importer and the label contact;
  • copies of bilingual labels where a labelling requirement or avoidable hazard applies.
Seven steps for Canada: confirm it is a cosmetic, check the Hotlist, collect INCI names and allergens, agree who files, prepare bilingual labels, notify within 10 days, update within 10 days.

Who files if you are based in Europe?

The guide explains that a foreign manufacturer without a Canadian address is represented by a responsible person in Canada, who counts as the manufacturer for this purpose. If nobody in Canada fits the definition of manufacturer, the importer is treated as the manufacturer. The form has also required a Canadian address for the manufacturer or importer since March 2025. For most European brands, this means agreeing with your Canadian importer or distributor in writing who files, who updates and who keeps the formula data.

The Cosmetic Ingredient Hotlist

The Cosmetic Ingredient Hotlist is Health Canada’s list of substances that are prohibited or restricted in cosmetics. It has two main parts: a table of prohibited ingredients and a table of restricted ingredients, with conditions of use, maximum concentrations and required warnings. Warnings from the restricted list must appear in both English and French. The page we checked is dated 2025, so download the current version before every formulation review.

If you already comply with the EU Annexes, you are partly there, but not completely. Compare your formula line by line against the Hotlist, because limits and bans can differ from the EU. Do not assume that an EU CPSR also covers Canada.

Read also Selling Cosmetics in Slovenia: Rules, Authorities and Labels

Bilingual labelling: English and French

Health Canada’s labelling guide says that on the outer label the product identity must appear in both languages on the principal display panel, and the net quantity must be bilingual as well. The metric symbols g and mL work in both languages, but unit words generally need translating. Other points from the guide include:

  • the ingredient list uses INCI names, in descending order of concentration, on the outer label;
  • for ingredients named in the Schedule to the Regulations, you need the EU name, or INCI plus the French equivalent; for example, “Water/Eau” rather than “Water” alone;
  • fragrance is declared as “parfum” and flavour as “aroma”;
  • the dealer’s name and principal place of business must appear with an address complete enough for postal delivery, and imports may show the foreign dealer or the Canadian dealer preceded by “imported by” or “imported for”;
  • required cautions, for example on pressurised containers, must be in both languages.

The guide also notes that supplementary French rules may apply in Quebec. Have a Canadian specialist review artwork before print.

Fragrance allergen labelling

Canada is phasing in fragrance allergen disclosure, with thresholds of 0.01% in rinse-off products and 0.001% in leave-on products. As set out in Health Canada’s guidance:

  • from 12 April 2026, new and existing cosmetics must disclose the allergens on the first list;
  • from 1 August 2026, new cosmetics must disclose the allergens on the expanded second list;
  • from 1 August 2028, existing products must do the same.

Allergens are listed separately from “parfum” and appear on the ingredient list. The Canadian list builds on the one in Annex III of the EU Regulation, so the work you did for Regulation (EU) 2023/1545 is a useful head start. Ask your fragrance supplier for allergen concentrations and check them against both lists.

Two people reviewing documents at a table

Is your product a cosmetic at all?

Products with therapeutic claims are usually not treated as cosmetics in Canada. Sun protection products, anti-dandruff shampoos and fluoride toothpastes, for example, are typically regulated as drugs or natural health products with their own rules. If your product has an SPF, an anti-acne claim or an antibacterial claim, ask Health Canada to confirm its classification before you commit to a launch date.

Read also Selling Cosmetics in Croatia: Rules, Authorities and Labels

What your EU documents give you

Health Canada does not ask for a CPSR in the EU format, as far as we could verify. Your EU file still helps because it is the most complete evidence of safety you are likely to have:

  • The CPSR documents ingredients, concentrations and exposure, which supply the data for the CNF and support your safety position if questions arise.
  • A stability test supports durability and packaging choices for shipping and shelf life.
  • A microbiological specifications test and a challenge test show that the product is clean and well preserved.
  • A patch test supports claims such as “tested on sensitive skin”.

Canada launch checklist

  1. Confirm the product is a cosmetic and not a drug or natural health product.
  2. Compare the formula with the Cosmetic Ingredient Hotlist.
  3. Gather INCI names and concentrations, including fragrance allergens.
  4. Agree with your importer who submits and updates the CNF.
  5. Prepare bilingual English and French labels, including cautions and the “parfum” wording.
  6. Submit the CNF within 10 days of first sale, and keep the notification number.
  7. Diary the 10-day updates for formula, name or contact changes and for discontinuation.

Common mistakes

  • Translating the label but forgetting the net quantity words or the cautions.
  • Leaving “fragrance” instead of “parfum” on the ingredient list.
  • Forgetting that a formula tweak triggers an amendment within 10 days.

How Cosmetic Testing Lab helps

We do not file the CNF or act as your importer. We provide the evidence: stability, microbiological, challenge and patch tests, a CPSR signed by a qualified safety assessor and a REACH-compliant 16-section SDS in more than 30 languages. DHL collects samples free from your door and you order online. Create a free account to unlock 10% off your first order and 20% on bundles.

Frequently asked questions

How long do I have to notify Health Canada?

The guide gives 10 days after the first sale in Canada. The same window applies to amendments and to discontinuation.

Do I need a Canadian company to sell cosmetics in Canada?

Someone in Canada has to be able to file the CNF as manufacturer or importer, and the form now requires a Canadian address. Many European brands use an importer or distributor for this.

Can I reuse my EU CPSR?

Not as a replacement for the Canadian steps, but it is valuable background. Check the formula against the Hotlist and the allergen rules before you rely on it.

Key takeaways

  • Notify with the CNF within 10 days of first sale, and update within 10 days of any change.
  • Check the formula against the Cosmetic Ingredient Hotlist, which can differ from the EU.
  • Labels need English and French, with “parfum”, bilingual cautions and phased-in fragrance allergens.
  • EU safety and test evidence is a strong base, but it does not replace the Canadian checks.
Sources (5)
Source Publisher Link
Notification of Cosmetics: Guide for Cosmetic Notifications Health Canada canada.ca/en/health-canada/services/consumer-product-safety/cosmetics/notification-cosmetics/guide.html
Industry Guide for the labelling of cosmetics Health Canada canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/industry-professionals/labelling-cosmetics.html
Cosmetic Ingredient Hotlist: Prohibited and Restricted Ingredients Health Canada canada.ca/en/health-canada/services/consumer-product-safety/cosmetics/cosmetic-ingredient-hotlist-prohibited-restricted-ingredients/hotlist.html
Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (SOR/2024-63) Canada Gazette, Part II gazette.gc.ca/rp-pr/p2/2024/2024-04-24/html/sor-dors63-eng.html
Commission Regulation (EU) 2023/1545 on fragrance allergen labelling European Union (EUR-Lex) eur-lex.europa.eu/eli/reg/2023/1545/oj

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