Preparing for the April 12 2026 Fragrance Allergen List

April 12, 2026 isn't far off if you sell scented products in Canada, and List 1 fragrance allergen disclosure becoming mandatory on both the CNF and the label is the kind of deadline that feels distant until it's three weeks away and you're realizing half your SKUs need new labels printed. Here's how to turn that date into an actual task list instead of a vague sense of dread.

What's changing on April 12

Starting on that date, List 1 fragrance allergens become mandatory both on your Cosmetic Notification Form and on your product label, not just a nice-to-have disclosure. The disclosure thresholds are set: above 0.001 percent, which is 10 parts per million, in leave-on products, and above 0.01 percent, which is 100 parts per million, in rinse-off products. Anything above those thresholds needs to be named specifically rather than folded into a generic "fragrance" or "parfum" line.

It's also worth knowing that a second, expanded set, List 2, becomes mandatory later on August 1, 2026, aligned with international allergen lists. So this isn't a one-time update. Treat April as the first of two label review cycles this year, not the only one.

Step 1: inventory every fragrance and essential oil you use

Start with a spreadsheet, one row per finished product, one column per fragrance or essential oil blend used in it. For each one, get the supplier's full breakdown of allergen content, not just the blend name. Common List 1 allergens include Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin, and they occur naturally in a lot of essential oils people don't think of as "fragrance" at all. Lavender, citrus oils, and many florals carry several of these allergens without any synthetic fragrance blend involved.

Step 2: do the math on concentration

This is the step people skip and regret. If your supplier's fragrance blend is used at 1 percent of your finished formula, and that blend contains 2 percent Linalool, the actual concentration of Linalool in your finished product is 0.02 percent, or 200 ppm, well above the leave-on threshold. Multiply the component percentage by the blend's use level every time. Doing this for every allergen in every fragrance across every product is tedious, but it's the only way to know which ones actually need to be named.

Step 3: sort your SKUs by product type

Product type	Threshold	Why it matters
Leave-on (lotion, cream, perfume)	Above 0.001% (10 ppm)	Lower threshold, more allergens likely to trigger
Rinse-off (soap, shampoo, cleanser)	Above 0.01% (100 ppm)	Higher threshold, fewer allergens likely to trigger

A fragrance oil used at the same percentage across a leave-on and a rinse-off line in your catalog might need disclosure on one and not the other, purely because of the threshold difference. Don't assume consistency across your line just because the fragrance is the same.

Step 4: update your CNF and your label artwork in tandem

Since both the notification and the label need the disclosed allergens by April 12, treat this as one task, not two. If you amend your Cosmetic Notification Form to add allergen entries but don't touch the physical label, or vice versa, you've created a mismatch between what's filed and what's on the shelf. Amendments are filed whenever a formula's ingredient declaration changes, and this counts.

Step 5: build a repeatable process for List 2

Since List 2 lands August 1, whatever process you build for List 1 (the spreadsheet, the multiplication step, the label update workflow) should be reusable for the second round rather than a one-off scramble. Save your calculations per SKU so you're not starting from zero in the summer.

If tracking allergen math across a full product catalog by hand sounds like a lot, it is, and it's one of the things Cosmetic Comply handles automatically: it carries supplier blend percentages through to finished-product concentrations and flags which allergens cross the leave-on or rinse-off threshold, so the April and August deadlines become a review step rather than a rebuild.