Fragrance Allergen List 1 and Your CNF After April 12 2026

If you filed a CNF a year ago and haven't touched it since, April 12, 2026 is the date that makes you go back and open it again. List 1 fragrance allergens become mandatory on both the CNF and the label as of that date, and the two obligations are connected in a way that's easy to underestimate if you've only been thinking about the label side.

What List 1 actually requires

List 1 is the original set of fragrance allergens that Health Canada has flagged for disclosure. It includes substances like Limonene, Linalool, Citronellol, Geraniol, and Eugenol, ingredients that occur naturally in a huge range of essential oils, not just synthetic fragrance compounds. If your soap has a lavender or citrus essential oil blend, there's a good chance several List 1 allergens are already in your formula whether you labeled for them before or not.

The disclosure triggers are concentration-based:

• Leave-on products: disclose above 0.001% (10 ppm).
• Rinse-off products: disclose above 0.01% (100 ppm).

Those are low thresholds. A fragrance oil used at 1% in a lotion can easily carry several allergens over the leave-on trigger once you do the math on the blend's composition.

Why this matters for your CNF, not just your label

It's tempting to treat this as a labeling update, add some words to the ingredient panel and move on. But the CNF is where Health Canada tracks what's actually in your product, and from April 12, 2026 the allergens crossing those thresholds need to be reflected there too. If your CNF was filed before you knew the fragrance blend's full allergen breakdown, or before this requirement existed, it may no longer be a complete and accurate notification of what's in the finished product.

This is where the file-versus-formula gap becomes a real compliance issue rather than a paperwork nuisance. An amendment is the mechanism for keeping the two in sync.

Getting the numbers you need

Your path to the correct concentrations runs through your fragrance or essential oil supplier:

1. Ask for the ingredient breakdown of any fragrance oil or essential oil blend, specifically which List 1 allergens it contains and at what percentage.
2. Multiply the allergen's percentage within the blend by the blend's use level in your finished product. A fragrance oil used at 1% that is 5% linalool contributes 0.05% linalool to the finished product, which is well above the leave-on threshold.
3. Repeat for every allergen the supplier discloses, since a single essential oil can carry three or four of them at meaningful levels.
4. Keep the supplier documentation on file. It's your evidence for the concentrations you declare.

Updating an existing CNF

If you already have a CN number for a product affected by List 1, the update path is an amendment, not a brand-new filing. You're telling Health Canada that the composition information on file needs to reflect the allergen concentrations you've now calculated. Discontinued products don't need this treatment, but anything still on shelves or in your online store does.

A quick reference

Item	Detail
Rule takes effect	April 12, 2026
Leave-on trigger	above 0.001% (10 ppm)
Rinse-off trigger	above 0.01% (100 ppm)
Common allergens to check	Limonene, Linalool, Citronellol, Geraniol, Eugenol, Coumarin
Filing mechanism for existing products	CNF amendment

Worth noting: List 2, an expanded allergen set aligned with international lists, becomes mandatory a few months later on August 1, 2026. If you're updating a CNF for List 1 now, it's worth asking your fragrance supplier for the List 2 breakdown at the same time so you're not doing this exercise twice in one year.

Cosmetic Comply carries these percentages through automatically once you've entered your fragrance blend's composition, so the allergen math and the CNF fields stay linked instead of living in two separate spreadsheets. If you're still tracking this by hand across several products, it's worth a look before the August deadline stacks on top of this one.