Canada & the CNF

How to Handle Parfum and Fragrance Blends on a CNF

How to declare a proprietary fragrance blend on a Canadian Cosmetic Notification Form when the supplier will not give you a full breakdown.

Diane R.4 min read

You email your fragrance supplier asking for the full composition of "Sweet Vanilla Musk No. 4," and you get back a friendly but firm reply: it is a proprietary blend, and they cannot share the full formula. This is a completely normal moment in cosmetic formulation, and there is a well-established way to handle it on a Cosmetic Notification Form.

Why suppliers hold fragrance formulas close

Fragrance houses treat their blends as trade secrets, often the most valuable IP they have. A single fragrance blend can contain dozens of aroma chemicals in specific ratios that took real R&D investment to develop. Unlike, say, a preservative blend where the two or three ingredients are usually disclosed on the technical data sheet, fragrance suppliers frequently withhold the complete formula even from their direct customers.

This is not the supplier being difficult. It is standard practice across the fragrance industry, and regulators built the CNF process with this reality in mind.

The "Parfum" or "Fragrance" declaration

On the notification, you can list "Parfum" (or "Fragrance," depending on the convention your filing uses) as a single ingredient entry at its total concentration in your finished product, rather than breaking out every individual aroma chemical inside it. This is the accepted approach precisely because full disclosure of proprietary blends is rarely available to the maker.

So if your lotion contains 1% of that vanilla musk fragrance oil, your notification lists "Parfum" at 1%, not twenty individual chemical names you do not have access to.

Where the allergen rules change this picture

Here is the part that is shifting in 2026 and worth understanding now rather than after the fact. Even though the overall fragrance blend can be declared as "Parfum," Canada's fragrance allergen disclosure rules require certain specific allergens within that blend to be broken out and declared individually, both on the CNF and on the label, once they are present above the relevant threshold.

List 1, the original fragrance allergen set, becomes mandatory on the CNF and label starting April 12, 2026. List 2, an expanded set aligned with international lists, becomes mandatory starting August 1, 2026. The disclosure trigger depends on whether your product is leave-on or rinse-off:

Product type Disclosure threshold
Leave-on (lotions, serums, leave-on hair products) Above 0.001% (10 ppm)
Rinse-off (cleansers, shampoos, soap) Above 0.01% (100 ppm)

Common allergens that show up in this context include Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin. These occur naturally in a huge number of essential oils, so this affects botanically fragranced products just as much as synthetic fragrance oil blends, often more, since natural essential oils can carry meaningfully higher levels of these constituents than a synthetic fragrance built to a target profile.

What this means practically for your fragrance supplier request

Even though you cannot get the full proprietary formula, you generally can and should ask your fragrance supplier for an allergen declaration specifically, a document listing which of the named allergens are present in their blend and at what concentration within the blend. Most established fragrance houses provide this exact document on request, separate from the full formula, because they know their customers need it for regulatory compliance in multiple markets. This is a narrower, more specific ask than "give me your whole formula," and it is one suppliers are generally set up to answer.

Once you have that allergen declaration, you multiply through the same way you would for any supplier blend: take the allergen's percentage within the fragrance blend, multiply by the blend's percentage in your finished product, and that gives you the allergen's true concentration in the finished product, which is what you compare against the 0.001% or 0.01% threshold.

A worked example

Say your fragrance supplier's allergen declaration shows Linalool at 2% within the fragrance blend, and you use that fragrance at 1% in a leave-on lotion. Linalool's real concentration in your finished lotion is 2% multiplied by 1%, which comes to 0.02%, well above the 0.001% leave-on threshold, so it needs individual declaration once the relevant list becomes mandatory.

Building this into your filing habits now

Even if your product's fragrance level is small, do not assume it falls under the threshold without doing the actual multiplication. Essential oil blends in particular can carry surprisingly high natural allergen content. Get the allergen declaration from every fragrance and essential oil supplier you use, keep it with your formulation records, and run the math per product rather than assuming.

Cosmetic Comply's ingredient matching handles this exact calculation, taking your fragrance blend's declared allergen content and your use level, and flagging which named allergens cross the leave-on or rinse-off threshold for your specific product, so the April and August 2026 deadlines do not catch you filing blind.

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