Fragrance Allergen Labeling in the EU vs the Rest

If you formulate with essential oils and sell into more than one market, you've probably already noticed that "fragrance allergen labeling" doesn't mean the same list, the same threshold, or the same deadline everywhere. The EU has had allergen disclosure rules in place for years. Canada is in the middle of rolling in a comparable system right now, in two stages, and the dates matter if you're filing there.

The EU baseline

Under Regulation (EC) No 1223/2009, certain fragrance allergens have to be individually listed by name in the ingredient list when they exceed set concentration thresholds, rather than being allowed to hide inside a generic "Parfum" or "Aroma" entry. The names you'll recognize on EU labels include Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin, among others. These aren't synthetic additives dreamed up by a lab. They occur naturally in common essential oils, which is exactly why a lavender or citrus-heavy formula can trigger multiple allergen declarations even when every ingredient came from a "natural" source.

Canada's rollout, in two waves

Health Canada is bringing in its own fragrance allergen disclosure requirement on a staged timeline, and it's worth having both dates on your calendar if you sell there:

• April 12, 2026: List 1, the original fragrance allergen set, becomes mandatory on both the Cosmetic Notification Form and the product label
• August 1, 2026: List 2, an expanded set aligned with international lists, becomes mandatory on top of List 1

The disclosure triggers are concentration-based, not a flat "contains fragrance" flag. In leave-on products, disclosure kicks in above 0.001% (10 ppm). In rinse-off products, the threshold is higher, above 0.01% (100 ppm), which makes sense given that rinse-off contact time and residual exposure are lower.

Where the two systems rhyme and where they don't

The EU and Canadian approaches share the same underlying logic, list specific allergens by name once they cross a concentration threshold, rather than let "fragrance" or "parfum" cover for everything. The overlap in the named substances is real too. Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin show up in both systems' allergen sets, since Canada's List 2 was built to align with international lists rather than invent a parallel taxonomy from scratch.

Where they diverge is mechanical:

Aspect	EU (1223/2009)	Canada (CNF)
Where declared	Ingredient list on label	CNF filing and label, both
Rollout	Already in force	List 1: Apr 12 2026, List 2: Aug 1 2026
Leave-on threshold	Set concentration threshold	Above 0.001% (10 ppm)
Rinse-off threshold	Set concentration threshold	Above 0.01% (100 ppm)
List scope	Established EU allergen list	List 1, then expanded List 2

What this means for your formula sheet

If you're selling the same essential-oil blend into both the EU and Canada, the smart move is to calculate every named allergen's finished-product concentration once and keep it on file, then check it against both markets' thresholds rather than treating each filing as a separate exercise. This matters even more for supplier fragrance blends. A blend's technical data sheet may quietly list Linalool at 8% of the blend itself. If you're using that blend at 1% of your total formula, the real concentration in your finished product is 0.08%, well above either threshold, and that math has to happen before you file, not after a regulator asks about it.

Essential oil blends are the usual surprise here. A "clean" ingredient deck full of botanicals can still carry six or more declarable allergens once you trace citrus, mint, and floral oils back to their allergen components.

Practical next step

If you already have an EU-compliant allergen declaration, don't assume it transfers automatically to a Canadian CNF filing. The named substances overlap heavily, but the format, the thresholds, and the timing are separate systems that both need to be satisfied on their own terms. Cosmetic Comply's Canadian filing flow is built to carry ingredient percentages through blends and flag allergen thresholds automatically as List 1 and List 2 come into force, which is one less spreadsheet to maintain by hand if you're juggling both markets at once.