One Foundation, Many Shades: How Many Notifications You File

Launching a foundation with a real shade range is one of the more satisfying moments for a small makeup brand, and also one of the more confusing ones when it comes time to file. Twelve shades, one product name, one base formula. Does that mean twelve Cosmetic Notification Forms, or one?

The honest answer is: it depends on what actually varies between the shades, and that comes down to concentration, not just the name on the tube.

What Health Canada is actually tracking

A Cosmetic Notification Form lists every ingredient by INCI name along with its concentration or concentration range. The point of the filing is to give an accurate picture of what is in the product being sold. If two shades of a foundation are genuinely the same base formula with only the pigment blend adjusted, and the colorant concentrations for each shade fall within a single declared range, that can often be captured as one notification with a concentration range covering the shade variation.

If the shades differ enough that a single concentration range would misrepresent what is actually in some of them, for example a very light shade using a small fraction of a percent of iron oxide while a deep shade uses several percent, then the honest filing is either a wider, accurate range that covers the full spread, or separate notifications for shades (or shade groups) that fall outside a reasonable shared range.

Where amendments come in

This is also where Health Canada's amendment process matters. If a foundation is already notified with a certain colorant range and the brand later adds two new deep shades that push colorant concentrations above the originally filed range, that is a formula change that calls for an amendment, not a new product launched quietly under the old CN number. The amendment path exists precisely for this kind of incremental formula shift, whether it is a shade addition, a preservative swap, or any other change to what is actually in the product.

A practical way to structure the filing

• List every shade's colorant blend and percentage before you file anything. You cannot know whether one range covers all your shades until you have the actual iron oxide, titanium dioxide, and mica percentages for each one side by side.
• Group shades with genuinely close colorant math under one range. A pale, fair, and light-medium set that only varies by fractions of a percent in colorant load is a reasonable single-range filing.
• Split out shades that are real outliers. A very deep or very warm-toned shade using meaningfully more colorant than the rest of the range may need its own filing or its own declared range to stay accurate.
• Treat future shade additions as amendments, not afterthoughts. Building this habit early avoids a scramble later.

A simplified example

Shade	Titanium dioxide	Iron oxides (combined)	Filing approach
Porcelain	3.0%	0.4%	Covered by base range
Light	3.0%	0.9%	Covered by base range
Medium	2.8%	1.6%	Covered by base range, if range set wide enough
Deep	2.2%	3.8%	Likely needs its own declared range or separate filing

The exact cutoffs depend on how the range is written in the original CNF, but the underlying logic is always the same: the filing has to accurately reflect what is actually in every shade sold under it.

Why this is worth getting right at launch, not after

Filing one overly broad CNF that quietly covers a huge colorant spread might feel efficient, but it stops being accurate the moment a shade sits well outside the declared range, and accuracy is the entire point of the notification. Getting the shade grouping right at launch is much less work than retrofitting amendments across a dozen SKUs after the fact.

Cosmetic Comply lets you duplicate a filed notification for a shade variant and adjusts the ingredient concentrations from there, which makes it straightforward to see at a glance whether a new shade fits inside an existing range or needs its own filing before it ships.