Fragrance Allergen List 2 Arrives August 1 2026: What Changes

List 1 gets most of the attention right now because it lands first, mandatory on the CNF and the label on April 12, 2026. But List 2 follows less than four months later, on August 1, 2026, and it is the wider net. If you only prepare for List 1 and treat List 2 as a later problem, you are setting yourself up to redo the same disclosure work twice in one year instead of once.

What List 2 actually is

List 1 was the original, narrower set of fragrance allergens that Canada has required disclosure for under existing conventions. List 2 is an expanded set, aligned more closely with broader international allergen lists, meaning it captures additional fragrance components beyond the original List 1 substances. Practically, this means ingredients that were not previously subject to mandatory disclosure in Canada will need to be identified and disclosed once List 2 takes effect.

The disclosure triggers themselves do not change between the two lists. Above 0.001 percent, that is 10 ppm, in a leave-on product, or above 0.01 percent, 100 ppm, in a rinse-off product, and the specific allergen has to be named on the CNF and the label rather than folded anonymously into "fragrance" or "parfum." What changes is which substances that rule applies to.

Why this matters even if you already handled List 1

A brand that did the List 1 work in the spring, mapping their fragrance blend, identifying Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin where present above threshold, might reasonably think the allergen disclosure project is finished. List 2 means going back into the same fragrance formula and checking it against a longer list of named substances. If your fragrance supplier's original allergen breakdown only covered List 1 substances because that was the standard at the time you sourced it, you likely need an updated breakdown from them that covers the List 2 additions too.

This is particularly relevant for natural and essential-oil-heavy formulas. Essential oils are complex mixtures that naturally contain multiple allergens at once, often several from both List 1 and List 2 in a single oil. A lavender or citrus-forward fragrance profile can easily carry more than one disclosable allergen once both lists are in effect, and missing the List 2 additions in an essential-oil-based formula is an easy way to end up with an incomplete disclosure.

A practical timeline

Date	Requirement
April 12, 2026	List 1 fragrance allergens mandatory on CNF and label
August 1, 2026	List 2 fragrance allergens mandatory on CNF and label

Four months is not a long runway if you are managing dozens of SKUs, each with its own fragrance blend, each needing a fresh allergen breakdown from a supplier who may be slow to respond during a period when every other brand is asking the same question at once.

What to do now rather than in July

• Request a full allergen breakdown from your fragrance supplier that explicitly covers both List 1 and List 2, not just the original narrower set. Ask directly whether their documentation has been updated for List 2.
• Recheck essential oils and botanical extracts specifically. These naturally contain multiple allergens across both lists, and suppliers of naturally derived fragrance materials may be slower to formalize allergen percentage breakdowns than synthetic fragrance house suppliers.
• Update label artwork planning now, since adding named allergens to an ingredient list is a label change, and label changes take lead time with packaging vendors.
• File amendments proactively rather than waiting for an inspection to prompt them. An existing CNF that predates List 2 disclosure will likely need an amendment once the new requirement is in force and the formula's allergen content is confirmed against the expanded list.

Don't treat this as a repeat of the same job

It is tempting to think of List 2 as "more of the same work we just did for List 1." The actual task, going back to your supplier, getting a complete percentage breakdown, checking thresholds, and amending both the CNF and the label, is genuinely the same task twice, just with a different reference list each time. Planning for both now, rather than sequentially as each deadline gets close, saves you from asking your fragrance supplier for the same kind of document twice in one year.

Cosmetic Comply tracks both allergen lists and their respective thresholds as part of the Canadian filing workflow, so when List 2 takes effect in August, the amendment path for an existing notification is a known step rather than a scramble.