Do Both 2026 Allergen Deadlines Apply to My Product

Two allergen deadlines are landing in Canada this year, close enough together that a lot of makers are asking us the same question: do I need to deal with both, or just one? The honest answer depends entirely on what is actually in your fragrance blend, so let's work through how to check it for your specific product instead of guessing from the calendar.

The two dates, quickly

List 1, the original fragrance allergen set, becomes mandatory on the CNF and the label on April 12, 2026. List 2, an expanded set aligned with international lists, becomes mandatory on August 1, 2026. If your formula contains only allergens from List 1, you are done once you handle the April date. If it contains anything from List 2 as well, or instead, you have a second round of work in August. Most fragrance-containing products end up touching both lists eventually, because common allergens like limonene and linalool that occur naturally in essential oils tend to appear across both sets.

Step one: does your product contain fragrance at all

This sounds obvious but it is the first place people skip ahead incorrectly. Unscented products, or products using only mineral or synthetic ingredients with no essential oils, botanical extracts, or fragrance or parfum blends, generally have nothing to disclose under either list. If your formula has no Parfum, Aroma, or essential oil listed anywhere, you can likely stop here, though it is worth double-checking any botanical extract for incidental fragrance-relevant compounds before assuming a clean pass.

Step two: pull your fragrance supplier's allergen declaration

If you do use fragrance, essential oils, or botanical extracts, get the actual allergen breakdown from your supplier rather than assuming based on the blend's marketing name. "Lavender Dreams" tells you nothing about what is inside it chemically. The declaration should list each allergen present in the blend and its percentage within that blend.

Step three: calculate your finished-product concentration

Multiply the allergen's percentage in the blend by your use level of that blend in the finished formula. If your fragrance oil is used at 0.5% and contains 4% linalool, your finished product has 0.02% linalool, which is 200 ppm.

Step four: check that number against your product's threshold

Disclosure triggers above 0.001% (10 ppm) in leave-on products and above 0.01% (100 ppm) in rinse-off products. A finished-product concentration of 200 ppm clears both thresholds easily. A concentration of 5 ppm would clear neither.

Step five: sort each allergen that clears the threshold into List 1 or List 2

This is the step that actually answers your original question. Once you know which allergens are present above threshold, you check each one against List 1 and List 2 separately.

Your situation	Deadline(s) that apply
No fragrance, no essential oils, no botanical extracts	Neither date affects you
Fragrance present, but every allergen above threshold is List 1 only	April 12, 2026 only
Fragrance present, allergens above threshold span List 1 and List 2	Both dates, April and August
Fragrance present, allergens above threshold are List 2 only	August 1, 2026 only, though this is less common since List 2 largely expands on List 1 rather than replacing it
Allergens present but all below both thresholds	Neither disclosure trigger fires, though it is worth rechecking after any formula change

Why essential oil blends usually land in both lists

Common allergens like limonene, linalool, citronellol, geraniol, eugenol, and coumarin occur naturally across many essential oils, and this is exactly why most fragrance-containing products end up touching both lists rather than just one. A citrus-forward blend is almost certain to carry limonene. A floral blend is likely to carry linalool and geraniol. If your product leans on essential oils rather than a single synthetic fragrance compound, budget time for both deadlines rather than hoping you will only need to handle one.

What actually needs to happen by each date

For April 12, 2026, any List 1 allergen above threshold needs to be named by INCI on both the CNF and the label. For August 1, 2026, the same applies to List 2 allergens. If a product touches both lists, you are not filing twice, you are making sure your one CNF and one label reflect the complete set of applicable allergens by the time each respective date arrives.

Running this calculation across several SKUs with different fragrance blends and use levels gets tedious fast, especially when blends get reformulated and you have to redo the multiplication each time. Cosmetic Comply carries the percentages through automatically when it maps a supplier blend to its components, and flags which allergens clear which threshold under List 1 and List 2, so you are not doing this arithmetic by hand product by product as both deadlines approach.