The 26 EU Allergens vs the Expanded Disclosure Set

For years, "the 26 allergens" was basically shorthand for fragrance allergen disclosure in cosmetics. Everyone in the industry knew the number, Limonene and Linalool were the two everyone could name off the top of their head, and the list felt settled. It isn't settled anymore. Regulators have been moving toward a broader disclosure set, and the gap between "the 26" and the newer expanded list is exactly the kind of thing that quietly outdates a label if nobody's paying attention.

The original baseline

The 26-allergen list has functioned as a long-standing reference point for fragrance allergen disclosure, built around substances known to commonly trigger skin sensitization or allergic reactions in a meaningful portion of the population. Names like Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin sit on this list, and all of them occur naturally in a wide range of essential oils, not just as synthetic additives. That's an important detail, because it means a "100% natural" fragrance profile isn't automatically allergen-free. A lavender essential oil can bring Linalool along with it just by being lavender.

Why an expanded set emerged

The original 26 were identified and settled some time ago, and cosmetic chemistry, fragrance formulation, and allergy research haven't stood still since. An expanded set has emerged internationally, aligning with newer scientific assessments of which fragrance components warrant disclosure, and it's meaningfully larger than the original 26. The exact composition of any expanded list can vary somewhat by jurisdiction, but the underlying idea is consistent: more fragrance components are now recognized as worth flagging to consumers than were recognized when the original list was drawn up.

The Canadian rollout, specifically

Canada's own fragrance allergen rules are moving in two stages, and this is worth having pinned down precisely if you sell there:

• List 1, which lines up with the original, long-standing allergen set, becomes mandatory on the Cosmetic Notification Form and on the product label as of April 12, 2026.
• List 2, the expanded set aligned with the broader international lists, becomes mandatory on August 1, 2026.

So there isn't one single deadline. There are two, roughly four months apart, and List 2 catches substances that List 1 doesn't. If you've only prepared your formulas and labels against List 1, you have a second wave of disclosure work coming before the summer is out.

Disclosure thresholds stay the same across both lists

Regardless of which list a specific allergen sits on, the thresholds that trigger mandatory disclosure in Canada don't change:

Product Type	Disclosure Threshold
Leave-on products (lotions, serums, facial oils, leave-in treatments)	Above 0.001% (10 ppm)
Rinse-off products (cleansers, shampoos, soaps)	Above 0.01% (100 ppm)

Leave-on products get the stricter threshold, which makes sense given the longer skin contact time. A facial oil with a trace of an essential oil is far more likely to cross that 10 ppm line than a body wash using the same essential oil at the same percentage, purely because the rinse-off threshold is ten times higher.

Where makers get caught off guard

The most common gap is essential oil blends. A "calming" blend combining lavender, chamomile, and bergamot might individually list each oil at a modest percentage in your formula, but each of those oils is itself a mix of dozens of aromatic compounds, several of which are named allergens on List 1 or List 2. You need to know not just how much essential oil blend you're using, but what allergen components are inside each oil in that blend, and at what concentration they land in your finished product after accounting for how much of the blend you actually used.

This is a multiplication problem much like working out a supplier blend's real concentration for any other ingredient category: take the percentage of the essential oil in your formula, then apply the known percentage of each allergen compound within that oil, to get the allergen's real concentration in the finished product. If that number crosses the relevant threshold for your product type, it needs disclosure, on the CNF and on the label.

Practical steps for the two 2026 deadlines

1. Get supplier documentation on the allergen composition of every essential oil and fragrance blend you use, not just the oil's common name.
2. Calculate each allergen's real concentration in your finished formula, accounting for use level.
3. Check trace amounts against both the List 1 and List 2 thresholds, since List 2 catches substances List 1 doesn't.
4. Update your CNF filings and labels ahead of April 12, 2026 for List 1, and again ahead of August 1, 2026 for List 2.
5. Don't treat this as a one-time check. If you reformulate a scent blend later, redo the allergen math for the new version.

Cosmetic Comply's ingredient mapping already resolves fragrance and essential oil components down to their INCI identities and expands blends into real concentrations, which is the same groundwork needed for allergen threshold checks. As the List 1 and List 2 deadlines approach, having that ingredient-level detail already sorted makes the disclosure step far less of a scramble.

Because the expanded list's exact scope and Canada's staged deadlines are the kind of detail that regulators can adjust, it's worth checking Health Canada's current fragrance allergen guidance directly as April and August 2026 get closer, rather than relying purely on what's documented today.