Health Canada’s New Cosmetic Regulations: What Brands Need to Know in 2024–2025
The cosmetics industry in Canada is undergoing major regulatory changes that will impact every manufacturer, importer, and brand selling personal care products. With Health Canada’s recent overhaul of the Cosmetic Regulations (SOR/2024-63) and updates to the Cosmetic Ingredient Hotlist, transparency and consumer safety are at the forefront.
In this blog, we break down the most important changes you need to know—and what your business must do to stay compliant.
What Changed? Overview of SOR/2024-63
In April 2024, Health Canada published a sweeping update to the Cosmetic Regulations—the most significant in over a decade. These changes come into effect October 9, 2024, with key provisions around fragrance allergens deferred until April 12, 2026.
New Definitions
The updated law clearly defines terms like:
- Manufacturer
- Importer
- Leave-on product vs. Rinse-off product
These definitions remove grey areas and ensure consistent interpretation across the industry.
Fragrance Allergen Disclosure (Effective April 12, 2026)
One of the biggest changes:
You must list specific fragrance allergens on the label if they are present above certain thresholds.
- Thresholds:
- Leave-on: ≥ 0.001%
- Rinse-off: ≥ 0.01%
- Applies to: 24+ common allergens (e.g., limonene, linalool)
- Small containers: You can use a QR code or website to share the full list
This aligns Canada more closely with European Union regulations, helping global brands standardize formulations and labels.
Cosmetic Notification Form Updates
If you sell a cosmetic in Canada, you must file a Cosmetic Notification Form (CNF) within 10 days of first sale. New requirements include:
- Declaring whether the product is leave-on or rinse-off
- Listing ingredients using INCI names
- Using a more detailed ingredient concentration table
As of March 5, 2025, the CNF must also include a Canadian address for the manufacturer or importer.
Modernized Labeling Requirements
Labels must now include:
- A method to contact the company (can be an email, website, or phone number—not just a postal address)
- Clear bilingual messaging if ingredients are listed online due to limited space
Enforcement Powers Increased
Health Canada now has authority to:
- Issue stop-sale orders for non-compliant products
- Request evidence of product safety
- Fine or restrict companies that fail to comply
Ingredient Watch: Hotlist Updates in 2024–2025
Health Canada’s Cosmetic Ingredient Hotlist outlines ingredients that are either prohibited or restricted in cosmetics sold in Canada. Several major updates were made in May 2024 and February 2025.
May 2024 Changes:
- New Prohibitions:
- Basic Green 4 (colorant)
- New Restrictions:
- Benzophenone
- Solvent Violet 13
- Hydroquinone (max 2%)
- Alpha Hydroxy Acids (AHAs) and Polyhydroxy Acids (PHAs)
February 2025 Changes:
- New Prohibitions:
- Thioglycolic acid esters (sensitizers)
- New Restrictions:
- Retinal (vitamin A derivative)
- Benzoyl peroxide (now limited to professional nail use only)
- Retinol concentrations revised for leave-on products
If you’re using any of these ingredients, double-check concentrations and permitted usage areas—or reformulate.
Key Compliance Deadlines
| Date | Requirement |
|---|---|
| Oct 9, 2024 | Updated Cosmetic Regulations come into force (except allergen disclosure) |
| Mar 5, 2025 | CNF must include a Canadian address |
| Apr 12, 2026 | Fragrance allergen disclosure becomes mandatory on packaging or online |
What Should Brands Do Now?
To stay ahead of the curve:
- Audit your labels: Ensure contact info, INCI names, and allergen policies comply.
- Review your formulations: Compare ingredients against the Hotlist regularly.
- Update your CNFs: Use the latest version and include all newly required details.
- Start planning for April 2026: Fragrance allergen disclosure may require packaging changes.
Final Thoughts
These regulatory changes reflect growing consumer demand for transparency, safety, and accountability in the beauty industry. While compliance will take effort, it’s also an opportunity to build consumer trust and align with global standards.
If you’re unsure how these updates apply to your products, consult a regulatory expert—or reach out to our team for guidance.
Need help navigating compliance?
Contact Fiducia Globus for product audits, CNF submissions, and regulatory consulting.
