April 2026 and August 2026 Allergen Deadlines Compared

Two dates keep coming up in questions from makers right now: April 12, 2026, and August 1, 2026. They're both about fragrance allergen disclosure in Canada, and they're both real, but they cover two different sets of allergens, which is where the confusion usually starts.

List 1 and List 2 are not the same thing

List 1 is the original fragrance allergen set. It becomes mandatory on the CNF and on the physical label on April 12, 2026.

List 2 is an expanded set of allergens, aligned with international lists, meaning it brings Canada's disclosure requirements closer in line with what other major markets already require. It becomes mandatory August 1, 2026, roughly three and a half months after List 1.

So these are not two versions of the same requirement rolling out in stages. They're two distinct groups of allergen substances, each with disclosure obligations that kick in at different times. A formula could clear List 1 screening with no issues and still need a second look under List 2 once August arrives, if it contains any of the additional substances only List 2 covers.

Why Health Canada staggered them instead of one cutover

Splitting the rollout gives makers, especially smaller ones without a dedicated regulatory team, a chance to handle the bigger and more commonly encountered List 1 allergens first: things like Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin, all of which occur naturally in a huge share of essential oils already sitting in soap and skincare formulas. Getting those right on your CNF and label is genuinely the bulk of the work for most small-batch formulators, since these six show up constantly in citrus, floral, and woody fragrance profiles.

List 2's expanded roster then follows a few months later, giving businesses time to review formulas against the newer, broader set without both waves landing on the same day.

What "mandatory" actually triggers

For both lists, the same underlying threshold logic applies:

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

Once a formula's allergen concentration crosses the relevant threshold for its product type, that allergen needs to appear both on the CNF filing and on the physical product label, in addition to being disclosed as part of the general ingredient declaration. The list determines which substances are being checked; the threshold determines whether disclosure is actually triggered for that substance in that specific formula.

A practical timeline for makers

Rather than treating these as two separate fire drills, it's worth building one habit that covers both:

1. Now through spring 2026: Pull the full fragrance and essential oil composition for every SKU you sell, and screen against List 1. Update labels and CNF filings for any product crossing a threshold, ahead of the April 12 deadline, not on it.
2. Spring through midsummer 2026: Do the same screening pass against List 2's expanded substance set. Because List 2 is broader, expect a few formulas that passed cleanly under List 1 to need disclosure once List 2 applies, ahead of the August 1 deadline.
3. Going forward: Any new product launched after both dates should be screened against both lists from the start, as a normal part of formulation, not as a separate compliance afterthought.

Don't wait for the deadline to do the math

The temptation is to treat April 12 and August 1 as the day the work needs to be done. In practice, the work is figuring out your actual allergen concentrations, which for a botanical-heavy formula can take real time, tracing linalool or limonene contributions across three or four different essential oils in the same fragrance blend. Starting that tracing exercise now, months ahead of either date, means you're updating labels calmly rather than reprinting packaging in a rush the week before a deadline.

Since these details are specific to Health Canada's current rules and could be refined before either date arrives, it's worth checking the regulator's own published lists directly if you're doing this calculation for a formula close to a threshold.

Cosmetic Comply tracks both List 1 and List 2 substances against your actual formula, expanding fragrance blends into their real components so the allergen math is done consistently across your whole catalog rather than product by product from scratch.