From 26 to 80 Fragrance Allergens: What Changed on Labels

If you learned fragrance allergen labeling years ago and haven't revisited it since, the number "26" is probably still stuck in your head as the full list you need to check. That number is about to become badly outdated for anyone selling in Canada, and it's worth understanding both what's changing and why the jump feels so much bigger than it actually is in practice.

The old world: a shorter, familiar list

For a long time, fragrance allergen disclosure centered on a set of around 26 named substances, things like Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin, each of which occurs naturally in a wide range of essential oils and fragrance compounds. If any of these showed up in your fragrance or essential oil blend above a certain threshold, you disclosed it by name on the ingredient list instead of letting it hide inside "Parfum" or "Fragrance."

That original set is what's referred to as List 1 in Canada's current rollout, and it becomes mandatory on both the Cosmetic Notification Form and the product label on April 12, 2026.

The expanded set: List 2

Following List 1, an expanded set of allergens, aligned with broader international lists, becomes mandatory on August 1, 2026. This is where people hear "80 allergens" and picture an entirely new, unfamiliar universe of ingredients to screen for. In reality, the expanded list builds on the same foundational chemistry. Many of the newly added substances are close relatives or co-occurring compounds found in the same essential oils and aroma chemicals that formulators already work with daily. The expansion reflects a broader effort to align allergen disclosure with international lists rather than a wholesale reinvention of what counts as an allergen.

Why this matters even if you don't add fragrance on purpose

Here's the part that surprises a lot of small-batch makers: you don't have to intentionally add a "fragrance allergen" for this to apply to you. These substances occur naturally inside many essential oils and botanical extracts. Lavender essential oil naturally contains Linalool. Citrus oils commonly contain Limonene. If your product's scent comes entirely from a blend of essential oils rather than a synthetic fragrance compound, you still need to screen for these allergens, because they arrive as natural constituents of the oils themselves, not as something you dosed in separately.

The two thresholds that decide if you disclose

Disclosure isn't triggered by any detectable trace. There are two clear thresholds, and which one applies depends on how the product is used:

Product type	Disclosure threshold
Leave-on products (lotions, serums, 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, lower threshold, which makes sense given prolonged skin contact compared to something rinsed away in under a minute. If an allergen from either list is present above the relevant threshold for your product type, it needs to be named individually on the ingredient declaration rather than folded into a generic fragrance listing.

What this means for your timeline

If you are formulating or relabeling right now, the practical move is to plan around both dates rather than treating April 12, 2026 as the finish line. A product launching in June 2026 that only accounts for List 1 will need another label update just two months later when List 2 becomes mandatory. It is far more efficient to screen your fragrance and essential oil components against both lists now, even though only List 1 is currently required, so your label artwork does not need a second revision cycle mid-year.

Getting the calculation right

To know whether you're above or below a threshold, you need your essential oil or fragrance blend's exact composition, not just an approximate sense of "there's a bit of citrus in there." A fragrance house can typically provide an allergen declaration for a compounded fragrance. For essential oils, allergen content varies by botanical source, growing conditions, and extraction method, so relying on a generic published average rather than your actual supplier's batch data can lead to under- or over-disclosure.

This is exactly the kind of ingredient-level detail that gets missed when allergen screening is done manually across a growing product catalog. Cosmetic Comply screens each formula's fragrance and essential oil components against the current allergen thresholds automatically, flags anything close to the leave-on or rinse-off cutoff, and carries that into your notification so the label and the filing stay in sync as List 1 and List 2 both come into force.