Preparing Supplier Documents for Allergen List 2 in August

If you already sorted out your fragrance allergen paperwork for April, you might think August is just more of the same. It's related, but it's not the same list, and the document request you send your fragrance and essential oil suppliers needs a second pass before summer.

Two lists, two dates

Canada's fragrance allergen disclosure rolls out in two stages. List 1, the original core set of fragrance allergens, becomes mandatory on the CNF and on the product label on April 12, 2026. List 2, an expanded set aligned with broader international allergen lists, becomes mandatory on August 1, 2026. If your supplier paperwork only covers List 1 substances, right now you have a gap for anything that's only on List 2.

The disclosure triggers don't change between the two lists: an allergen needs to be disclosed if it's present above 0.001% (10 ppm) in a leave-on product, or above 0.01% (100 ppm) in a rinse-off product. What changes is which substances you're required to check for.

Why List 2 catches more people off guard

List 1 covers the allergens most formulators already know by name, things like limonene, linalool, citronellol, geraniol, eugenol, and coumarin, largely because these have been flagged internationally for years and show up constantly in essential oils. List 2 broadens that set. Because it's less familiar territory, it's easy to assume your existing supplier documentation already covers it when it doesn't.

This matters most for essential oil and natural fragrance users. A single essential oil can carry half a dozen allergens across both lists at meaningfully different concentrations, and a supplier's older certificate of analysis may only speak to the substances that were commonly requested a year or two ago.

What to actually request from suppliers now

Don't wait until July to start this. Go back to every fragrance and essential oil supplier you use and ask for an updated composition breakdown that explicitly states the concentration of every substance covered by both List 1 and List 2, not just "contains natural allergens" boilerplate. Specifically ask for:

• A full component breakdown of the fragrance or essential oil, by INCI name, with percentage or percentage range for each component
• Explicit confirmation of concentration for any List 2 substance present, even at trace level
• An updated date on the document, since older certificates may predate a reformulation on the supplier's end
• A named contact for follow-up questions, since allergen composition can shift between production lots for natural materials

Building your internal tracking

A simple table per fragrance or essential oil keeps this manageable:

Fragrance/EO name	Supplier	List 1 allergens present	List 2 allergens present	Doc date	Disclosure threshold met?
Lavender EO, Lot 4421	Supplier A	Linalool, Geraniol	(List 2 substance)	2026-02-01	Yes, leave-on

Update this whenever a new lot arrives or a supplier issues a revised document. Natural materials vary lot to lot more than synthetic fragrance compounds do, so a document from last year isn't a safe stand-in for this year's batch.

Don't forget the label side

The CNF disclosure and the label disclosure move together on these dates. Getting the ingredient list right on your filing doesn't help if your printed or online label copy wasn't updated to match once List 2 kicks in on August 1. If you print labels in batches, build a checkpoint into your production calendar now so you're not sitting on stock printed with an outdated ingredient declaration after the deadline passes.

If you're not sure whether something applies to you

The safest approach is to treat every fragrance or essential oil-containing product as needing a full allergen review against both lists, even ones you consider low-risk. A "light" essential oil blend can still carry a disclosable amount of an allergen most people wouldn't guess at without lab data or a proper supplier breakdown.

This is exactly the kind of detail Cosmetic Comply is built to catch, since it flags allergen-relevant ingredients against both List 1 and List 2 as part of screening your formula, so you're not relying on memory for which fragrance compounds carry a disclosure obligation and which don't.