Fragrance Allergen List 1 and What to Ask Suppliers Now

If you sell fragranced cosmetics into Canada, April 12, 2026 is the date to have circled. That's when List 1 fragrance allergen disclosure becomes mandatory on both the CNF and the product label, and if you haven't already gone back to your fragrance and essential oil suppliers for allergen breakdowns, now's the time.

What List 1 actually requires

List 1 is the original set of fragrance allergens that Health Canada requires you to disclose once they're present above certain thresholds: above 0.001% (10 ppm) in leave-on products, above 0.01% (100 ppm) in rinse-off products. Common List 1 allergens include Limonene, Linalool, Citronellol, Geraniol, and Eugenol, along with Coumarin. These aren't exotic synthetic additives most of the time. They occur naturally in a huge range of essential oils, which is exactly why so many indie and small-batch makers get caught off guard. Lavender oil carries Linalool and Linalyl Acetate. Citrus oils carry Limonene. Rose and geranium carry Geraniol and Citronellol. If your "fragrance-free but essential-oil-scented" soap uses lavender, you likely have allergens to disclose regardless of how natural the ingredient feels.

The exact ask to send suppliers

A generic "send me your SDS" email won't get you what you need, because most safety data sheets are written for workplace hazard communication, not allergen percentage disclosure. Section 3 of an SDS lists composition, but it often groups fragrance components under a trade name or lists them only above OSHA-type hazard thresholds, which are usually much higher than Health Canada's allergen thresholds.

Ask your supplier for:

1. A full allergen declaration for the specific fragrance oil or essential oil lot, listing each List 1 allergen present and its percentage or a percentage range
2. Confirmation of whether the declaration reflects the current formulation, since suppliers sometimes reformulate fragrance oils without renaming them
3. The CAS number for each declared allergen, so you can cross-check it against Health Canada's list without relying on the trade name

Reputable fragrance houses already have allergen declarations on file because the EU has required this kind of disclosure for years under Regulation (EC) No 1223/2009. If your supplier can produce an EU-style allergen statement, it usually maps directly onto what you need for List 1.

Doing the math on a blend

Suppose a fragrance oil is used at 1% in your lotion, and the supplier's allergen declaration says that fragrance oil contains 3% Linalool. The real concentration of Linalool in your finished product is 0.03% (1% times 3%), which is 300 ppm, well above the leave-on threshold of 10 ppm. That one line item alone would need disclosure. This is the same multiply-through logic that applies to any supplier blend: take the component percentage inside the blend, multiply by how much of the blend you use, and that's the real number that matters for your filing.

Allergen	Common source	Disclosure trigger (leave-on)	Disclosure trigger (rinse-off)
Limonene	Citrus oils	Above 0.001% (10 ppm)	Above 0.01% (100 ppm)
Linalool	Lavender, many florals	Above 0.001% (10 ppm)	Above 0.01% (100 ppm)
Citronellol	Rose, geranium	Above 0.001% (10 ppm)	Above 0.01% (100 ppm)
Geraniol	Rose, geranium, citronella	Above 0.001% (10 ppm)	Above 0.01% (100 ppm)
Eugenol	Clove, cinnamon leaf	Above 0.001% (10 ppm)	Above 0.01% (100 ppm)
Coumarin	Tonka bean, some synthetics	Above 0.001% (10 ppm)	Above 0.01% (100 ppm)

Why this can't wait until March

Reformulating a fragrance load or renegotiating a supplier relationship takes time you don't want to be doing in the two weeks before a mandatory date hits. Getting allergen data now also gives you room to decide whether you actually want to keep an ingredient at a level that requires disclosure, or whether a small tweak keeps it under threshold and off the label entirely.

Keep in mind List 2, an expanded allergen set aligned with international lists, becomes mandatory a few months later on August 1, 2026, so whatever supplier conversation you're having now is worth extending to cover both lists at once rather than doing this twice.

Cosmetic Comply carries allergen percentages through from supplier blend to finished product automatically once you've entered the breakdown, which saves you from doing this multiplication by hand across every fragranced SKU you sell.