Allergen Declaration Checklist Before You File

There's a specific moment in the filing process where allergen disclosure goes wrong, and it's rarely the concept that trips people up. Makers understand the idea fine. It's the execution, the missing supplier document, the math done on the wrong base percentage, the label statement placed in the wrong spot, that turns a straightforward requirement into a resubmission. Here's a working checklist to run before you file, not after.

Step 1: Confirm which list applies to your filing date

List 1, the original fragrance allergen set, becomes mandatory on the CNF and on labels on April 12, 2026. List 2, an expanded set aligned with broader international lists, becomes mandatory on August 1, 2026. If you're filing before April 12, 2026, List 1 disclosure isn't yet mandatory, but building the habit early costs you nothing and saves a scramble later. If you're filing between the two dates, you need List 1 covered. After August 1, 2026, both lists apply.

Step 2: Get supplier allergen data for every fragrance and essential oil

This is the step most often skipped, not because people don't know it matters but because it means going back to a supplier for a document they didn't originally send.

• Fragrance oil supplier's allergen declaration (percentage of each relevant allergen present in the oil itself)
• Essential oil supplier documentation, since naturally derived oils carry allergens too, citrus oils commonly carry Limonene, many florals carry Linalool and Geraniol, clove and cinnamon-adjacent oils carry Eugenol and Coumarin
• Confirmation of whether the declaration covers List 1 only or both lists

If a supplier can only offer a generic "may contain common allergens" statement without percentages, that's not enough to do the math in the next step. Push for actual numbers.

Step 3: Do the concentration math correctly

The finished-product concentration of an allergen is not the same as your fragrance oil's use level in the formula. It's the fragrance oil's use level multiplied by the allergen's share of that oil.

Example: your lotion uses fragrance oil at 0.8% of the total formula. The supplier's declaration says that oil is 3% Linalool by weight. The finished-product concentration of Linalool is:

0.8% x 3% = 0.024%, or 240 ppm.

Step 4: Compare against the correct threshold for your product type

• Leave-on product: disclosure required above 0.001% (10 ppm)
• Rinse-off product: disclosure required above 0.01% (100 ppm)

Using the example above, 240 ppm clears both thresholds easily, so Linalool needs disclosure whether the lotion is leave-on or, hypothetically, rinsed off. But plenty of real cases sit closer to the line, especially in rinse-off products at lower fragrance use levels, so don't skip the actual comparison just because the math felt like a formality.

Step 5: Repeat for every allergen in every fragrance component

If your fragrance oil declaration lists five allergens, do the math for all five separately. Don't assume that because one clears the threshold, the rest do too, or that because one doesn't, none of them do. Each compound has a different share of the oil and needs its own line.

Allergen	Share of fragrance oil	Fragrance use level	Finished concentration	Threshold (leave-on)	Disclose?
Linalool	3%	0.8%	240 ppm	10 ppm	Yes
Limonene	1.5%	0.8%	120 ppm	10 ppm	Yes
Coumarin	0.05%	0.8%	4 ppm	10 ppm	No

Step 6: Place the disclosed allergens correctly on the CNF and the label

• Allergens above threshold added to the ingredient declaration in descending concentration order alongside your other ingredients, not as a separate footnote
• Same allergens reflected on the CNF filing itself, not just the printed label
• Concentration ranges filed accurately, matching whatever range your batch-to-batch variation actually supports

Step 7: Recheck when anything upstream changes

A fragrance supplier reformulation, a new essential oil supplier, or a change in your fragrance use level all reset this checklist. Treat allergen disclosure as tied to the current formula, not a one-time task you finish and forget.

Running this checklist by hand across a full product line is genuinely tedious, which is exactly the kind of repetitive, error-prone math Cosmetic Comply automates. It takes the supplier's allergen percentages, carries them through your formula's use levels, checks them against the leave-on and rinse-off thresholds, and flags what needs disclosure before a human reviewer signs off, so step 3 through step 6 above stop being a spreadsheet you maintain by hand for every SKU.