A Line-by-Line Checklist for Screening a Formula

Every maker eventually asks the same question before their first Health Canada filing: where do I even start checking my formula? The honest answer is one ingredient at a time, methodically, with a system you can repeat for every product after this one. Here is the checklist we walk clients through.

Step 1: Get every ingredient to its INCI name

Before you can screen anything, you need the actual INCI names, not trade names or supplier marketing terms. "Vitamin E oil" is not a filing entry. Tocopherol is. If a supplier sold you a blend, you need its full component breakdown, not just the blend name on the drum.

• Pull the actual supplier spec sheet or SDS for every raw material
• Confirm the INCI name for each one, including botanicals and extracts
• Note the CAS number where one exists (some botanical extracts genuinely have none, and that is normal)
• Flag any blend that needs to be expanded into its individual components

Step 2: Calculate real concentrations, not batch percentages

This is where a lot of self-filed formulas go wrong. If a preservative blend is used at 1% of your finished product, and that blend is itself 20% phenoxyethanol, the real concentration of phenoxyethanol in your finished product is 0.2%, not 1%. You multiply the component percentage by the blend's use level. Do this for every blended ingredient before you screen anything.

Step 3: Run each INCI name against the Hotlist

The Cosmetic Ingredient Hotlist is Health Canada's list of substances that are prohibited outright or restricted with conditions like a concentration ceiling, a required warning statement, or a limited use category. For each ingredient on your list:

1. Search the exact INCI name, not a close variant
2. Check whether it appears as prohibited (in which case it cannot be in the product at all)
3. Check whether it appears as restricted, and note the specific condition attached, whether that is a maximum percentage, a required label statement, or a use restriction
4. Confirm your finished-product concentration sits under any ceiling with some margin, not right at the edge

Step 4: Check for category-specific rules

Some restrictions depend on how the product is used. A rinse-off product and a leave-on product can face different limits for the same ingredient. Products intended for children or the eye area sometimes carry tighter conditions too. Make sure you are checking the Hotlist entry that matches your actual product type and intended use, not just the ingredient name in isolation.

Step 5: Watch for the fragrance allergen changes

If your formula includes essential oils, fragrance blends, or botanical extracts, remember that common allergens like limonene, linalool, citronellol, geraniol, eugenol, and coumarin occur naturally in many of them, even in formulas with no added "fragrance" ingredient. Canada's disclosure rules are shifting on a set schedule: the original List 1 allergen set becomes mandatory on the CNF and label on April 12, 2026, and an expanded List 2 becomes mandatory on August 1, 2026. Disclosure is triggered above 0.001 percent in leave-on products and above 0.01 percent in rinse-off products. If you have not recalculated your allergen percentages since adding a new essential oil to a formula, do it now rather than at filing time.

Step 6: Document your reasoning

For every ingredient that showed up as restricted, keep a short note of what condition applies and how your formula satisfies it. This is not required paperwork in the way an SDS is, but it saves enormous time later if a reviewer or a retailer asks why a particular ingredient is safe at your concentration.

A simple reference table

Screening step	What you are checking	Common mistake
INCI mapping	Trade name to correct INCI	Filing the trade name instead
Blend expansion	Component percentage times use level	Filing the blend percentage as the actual concentration
Hotlist match	Exact INCI name against prohibited/restricted entries	Matching a similar-sounding ingredient instead
Category check	Rinse-off vs leave-on, child-directed or not	Applying a general limit that does not fit the product type
Allergen recheck	Natural allergen content from essential oils	Assuming no added fragrance means no allergens

Running this checklist by hand for a ten-ingredient formula is manageable in an afternoon. Running it for a twenty-product line with shared preservative systems and rotating essential oil blends is where most makers start looking for help. Cosmetic Comply automates exactly this sequence: it maps every ingredient to its INCI name and CAS number, expands supplier blends into real percentages, screens each one against the current Hotlist with a confidence score, and has an actual compliance reviewer confirm the result before anything gets filed. Whether you use a tool or a spreadsheet, the sequence above is the one that catches problems before a customer does.