CNF Concentration Range Brackets Cheat Sheet

Every time I walk a new filer through their first Cosmetic Notification Form, the same question comes up: do I have to put the exact percentage, or can I use a range? You can use a range, and honestly, most experienced filers prefer it, because it protects minor formula tweaks from triggering a fresh amendment every time a supplier's batch varies by half a percent.

Why ranges exist on the CNF

Health Canada's Cosmetic Notification System lets you declare each ingredient's concentration either as an exact percentage or as a bracketed range. The logic is practical: cosmetic formulas shift slightly between batches for all sorts of reasons, from raw material lot variation to minor reformulation for cost or supply reasons. If every 0.1 percent shift required a new notification, the system would be unworkable both for filers and for Health Canada's own review capacity. Ranges give you room to operate without re-filing constantly, as long as your actual concentration stays inside the bracket you declared.

The standard bracket set

While exact bracket boundaries can be adjusted by Health Canada from time to time, the general convention filers use groups concentrations into bands, tightening as you move toward the lower end of the scale where small differences matter more for safety review purposes, and widening at the higher end where broad categories like water or base emollients dominate. A typical bracket structure looks like this:

Ingredient concentration	Typical bracket used
Above 50%	50 to 100%
25 to 50%	25 to 50%
10 to 25%	10 to 25%
5 to 10%	5 to 10%
1 to 5%	1 to 5%
0.1 to 1%	0.1 to 1%
Below 0.1%	0.01 to 0.1%, or exact trace value

Because Health Canada may refine these bands, always confirm the current bracket list in the Cosmetic Notification System at the time you file rather than relying on a bracket table from an old filing or a blog post. Brackets are a moving target in the sense that the system's exact cutoffs can be updated, even though the underlying logic of "declare a range that contains your true concentration" does not change.

The decision rule for borderline percentages

Here is the rule that keeps filers out of trouble: if your actual concentration sits close to a bracket boundary, always select the bracket that fully contains your value with margin, not the bracket that just barely captures it.

Say your preservative sits at 0.95 percent by formula, but your manufacturing tolerance means a given batch could run as high as 1.05 percent. Do not declare "0.1 to 1%" just because your target is 0.95. Declare "1 to 5%" instead, since that bracket safely contains any realistic batch variation above 1 percent. The goal of the bracket is to describe the true range your product could ever fall into, not just your target formula value on paper.

A simple way to apply this in practice:

1. Identify your ingredient's target percentage from the formula.
2. Add your realistic manufacturing tolerance, often plus or minus a percent or two of the target value depending on your process controls.
3. Choose the bracket that comfortably contains the full span, including the tolerance.
4. If the tolerance pushes you across a bracket boundary, choose the wider bracket, not the narrower one.

Why this matters for restricted ingredients specifically

For ingredients that appear on the Cosmetic Ingredient Hotlist with a maximum permitted concentration, the bracket you declare has to stay entirely under that ceiling, not just close to it. If a Hotlist entry caps an ingredient at 1 percent and your bracket selection is "0.1 to 1%," you are telling Health Canada your product could contain up to 1 percent, which is the legal edge. If your actual manufacturing process sometimes nudges slightly over that due to normal variation, you have a real compliance exposure regardless of what bracket you selected. Build in headroom below the regulatory ceiling, not right up against it.

When to re-file instead of relying on the bracket

Brackets absorb minor natural variation. They do not excuse a genuine reformulation. If you deliberately change your target concentration such that it now sits in a different bracket than your original notification, or you add or remove an ingredient entirely, that calls for an amendment, not a shrug that the range "probably still covers it." The bracket system is meant for batch-to-batch noise, not for formula changes you made on purpose.

If you are managing a growing product line and want to avoid manually re-deriving brackets every time a formula shifts, this is one of the areas where a tool like Cosmetic Comply pays for itself. It carries concentrations through from your ingredient list, applies the current bracket logic, and flags anything sitting close enough to a Hotlist ceiling that you should double check your manufacturing tolerance before you file.