What an Allergen Declaration Document Contains and Why

Ask a fragrance house for a safety data sheet and you'll get one without hesitation, sixteen sections, composition in section 3, all standard. Ask for an allergen declaration and sometimes you get a blank look, sometimes you get the SDS again with a shrug, and occasionally you get exactly the right document. The confusion is understandable because these two documents overlap in purpose but aren't the same thing, and knowing the difference saves you a scramble later.

Why the SDS alone usually isn't enough

An SDS is built around worker safety and handling, not consumer-facing allergen disclosure. Section 3 lists composition, but fragrance formulas are frequently protected as trade secrets, and a supplier can legally disclose a fragrance blend as "fragrance" or "parfum" in that section without breaking out the individual allergenic components. That's fine for its intended purpose. It's not fine if you need to know whether your rose-scented lotion contains geraniol above the disclosure threshold.

An allergen declaration exists specifically to close that gap. It's a document, sometimes a standalone PDF, sometimes an appendix to the SDS, whose entire job is to itemize the specific allergenic components present in a fragrance or essential oil, even when the full formula stays confidential.

What a proper allergen declaration should include

A useful allergen declaration document typically covers:

• The specific allergens present, named individually rather than lumped as "fragrance allergens may be present"
• Concentration of each allergen, given as a percentage or in ppm, within the fragrance or oil itself
• The reference list or standard the declaration is checked against, since different regions track different allergen sets
• A statement of "not present" or "below detection limit" for allergens the supplier tested for but didn't find, which is more useful than silence
• Batch or lot traceability, so you know the declaration actually corresponds to the material you received rather than a generic average

Canada's disclosure framework centers on two allergen lists. List 1 is the original fragrance allergen set becoming mandatory on the Cosmetic Notification Form and the label on April 12, 2026. List 2 is an expanded set aligned with international allergen lists, becoming mandatory August 1, 2026. A good declaration document should map cleanly to whichever list matters for your market, ideally both, since you'll need List 2 coverage well before the second deadline arrives if you want time to reformulate anything that doesn't clear.

The two thresholds that decide what gets disclosed

Whether an individual allergen needs to appear on your notification and your label comes down to concentration in the finished product, not concentration in the raw fragrance or oil:

Product type	Disclosure threshold
Leave-on products	Above 0.001% (10 ppm)
Rinse-off products	Above 0.01% (100 ppm)

This is exactly why the declaration needs to state concentration within the fragrance or oil itself. You take that number, multiply by your use level of that fragrance or oil in the finished formula, and compare the result against the threshold for your product type. A fragrance oil declaring 2% linalool, used at 0.5% in a leave-on cream, works out to a tiny fraction of a percent in the finished product, small, but potentially still over the leave-on threshold once you run the math.

Common allergens you'll see named

Limonene, linalool, citronellol, geraniol, eugenol, and coumarin show up constantly across both natural essential oils and synthetic fragrance compounds, since several of them occur naturally in citrus, rose, and clove-type materials as much as in lab-formulated fragrance blends. A declaration document that's actually thorough will name these specifically rather than gesturing at "may contain natural fragrance allergens" as a catch-all.

Asking your supplier the right way

If you're not currently getting a proper allergen declaration, the ask is simple: request a document, separate from the general SDS, that lists each disclosable allergen present in the specific fragrance or essential oil you're buying, with a percentage or ppm figure for each. Reputable suppliers serving the Canadian and EU markets already have this ready, since EU notification has required allergen-level detail for some time. If a supplier can't produce it, that's a signal worth taking seriously before your April and August 2026 deadlines arrive.

Once you have that documentation in hand, Cosmetic Comply's matching workflow carries the allergen percentages through your actual formula, applies the leave-on or rinse-off threshold correctly, and flags anything that needs to make it onto your CNF filing and label before a reviewer signs off.