Fragrance Allergen List 1 and Your April 2026 Perfume Deadline

If you make perfume, this deadline hits you harder than almost anyone else in the cosmetics space, simply because your product is fragrance. A body lotion has a fragrance component. A perfume basically is one. April 12, 2026 is when List 1 fragrance allergen disclosure becomes mandatory on both the Cosmetic Notification Form and the label in Canada, and for concentrated scent products, that date deserves real attention now rather than a scramble in March.

Why perfume feels this one differently

Most cosmetic categories carry fragrance as one ingredient among many, often at a fraction of a percent. A perfume or cologne is the fragrance, frequently at concentrations many times higher than what shows up in a lotion or shampoo. That has a direct consequence for allergen disclosure: the same List 1 substances, Limonene, Linalool, Citronellol, Geraniol, Eugenol, Coumarin among them, that might sit right at or under the disclosure threshold in a diluted body product can be present at meaningfully higher levels in a fine fragrance, simply because the whole product is concentrated aromatic material.

The disclosure triggers themselves aren't different for perfume versus any other product category. It's still above 0.001 percent (10 parts per million) for leave-on products, which is where perfume sits, and above 0.01 percent (100 parts per million) for rinse-off products. But because a perfume's overall fragrance concentration is so much higher than a typical lotion's, it's far more likely that several List 1 allergens individually clear that leave-on threshold in a single formula, not just one.

What you actually need to do before April 12, 2026

1. Get the full breakdown of your fragrance oil or perfume concentrate. If you buy your fragrance as a finished blend from a supplier or fragrance house, you need their documentation on which List 1 allergens are present and at what percentage of the blend, not just a trade name like "Amber Vanilla No. 4."
2. Calculate real finished-product concentrations. Multiply each allergen's percentage within the fragrance blend by how much of that blend is used in your final perfume or spray. A blend that's 2 percent Linalool, used at a 20 percent concentration in an eau de parfum, works out to 0.4 percent Linalool in the finished bottle, which is very comfortably above the leave-on disclosure threshold.
3. Update your CNF filing to reflect each List 1 allergen present above threshold, by its own INCI name and concentration, ahead of the April deadline.
4. Update your label artwork to include the same disclosures, which for many perfume brands means a redesign of already-tight label space, since fine fragrance packaging tends to prioritize aesthetics over information density.
5. Plan your production and packaging timeline backward from April 12, 2026, since relabeling a fragrance line takes longer than people expect once you factor in new printing runs and existing inventory in old packaging.

Don't lose track of List 2

List 1 is the nearer deadline, but List 2, the expanded allergen set aligned with international lists, becomes mandatory on August 1, 2026, only a few months later. If you're already redoing your fragrance breakdown and label artwork for List 1, it's worth checking your formula against List 2's expanded scope in the same pass rather than repeating the whole exercise twice in one year.

A simple way to track it

Where to get the underlying numbers

Because a fine fragrance is essentially a stack of aromatic materials, several sourced as proprietary blends, tracing allergen content through the whole formula by hand is genuinely time-consuming and easy to get slightly wrong. This is exactly the kind of ingredient expansion Cosmetic Comply is built to do, taking a supplier blend, expanding it into its named components, and carrying the percentages through to the finished product so the CNF and label reflect real concentrations rather than estimates. With April 12, 2026 closer than it feels, getting that breakdown done now, rather than the week before, is worth the head start.