The List 1 Fragrance Allergens and Their INCI Names

April 12, 2026 is closer than it feels when you're mid-batch. That's the date List 1 fragrance allergens become mandatory on both the Cosmetic Notification Form and the physical label in Canada, and if your notification currently just says "Parfum" or "Fragrance" and calls it a day, you have a bit of homework ahead of you.

What List 1 actually is

List 1 is the original, longer-established set of fragrance allergens that regulators have flagged as common sensitizers. It's not new science. These are the same names that have shown up on ingredient lists in the EU for years. What's changing is that Canada is now requiring them to be broken out explicitly rather than folded into a generic "Parfum" entry, on both the CNF and the label itself.

The threshold that decides whether you need to list one is based on concentration in the finished product:

• Leave-on products (lotions, serums, perfumes worn on skin): disclosure required above 0.001% (10 ppm)
• Rinse-off products (shampoo, soap, body wash): disclosure required above 0.01% (100 ppm)

Those are low numbers. A fragrance oil doesn't need to be heavily dosed for one of its component allergens to cross that line, especially in a leave-on product.

Common List 1 allergens and their INCI names

These are named by their INCI terms directly, since that's the standardized name you'd put on both the CNF and the label:

Common allergen	INCI name used on label/CNF	Where it commonly occurs naturally
Limonene	Limonene	Citrus essential oils (orange, lemon, bergamot)
Linalool	Linalool	Lavender, coriander, many floral oils
Citronellol	Citronellol	Rose, geranium, citronella oils
Geraniol	Geraniol	Rose, palmarosa, geranium oils
Eugenol	Eugenol	Clove, cinnamon leaf oil
Coumarin	Coumarin	Tonka bean, some lavender and cassia

Notice that none of these require you to add a synthetic chemical to trigger disclosure. They occur naturally, sometimes at meaningful concentrations, in essential oils that makers reach for specifically because they're "natural." A lavender-scented lotion can trip the linalool threshold from the lavender oil alone, with zero synthetic fragrance in the formula.

Why "natural" doesn't get you out of this

This catches a lot of makers off guard, especially ones using essential oil blends instead of commercial fragrance oils. The assumption is often that allergen disclosure is a synthetic-fragrance problem. It isn't. Limonene shows up in nearly every citrus peel oil. Linalool shows up in dozens of floral and herbaceous oils. If you're formulating with essential oils, you likely already have List 1 allergens in your product, you just haven't had to name them yet.

The practical step is to get a composition breakdown for whatever essential oil or fragrance blend you're using; supplier documentation or an SDS should list the major aromatic constituents and roughly what percentage they make up of the oil. From there, multiply that percentage by how much of the oil you're using in the finished product to see if any single allergen crosses the 0.001% or 0.01% threshold.

A worked example

Say you use 1% lavender essential oil in a leave-on lotion, and your supplier's documentation shows the oil is roughly 30% linalool. That works out to 0.3% linalool in the oil itself, times the 1% use rate, which lands around 0.003% linalool in the finished lotion. That's above the 0.001% leave-on threshold, so linalool needs to appear on both the CNF and the label once the mandatory date arrives.

Getting ready before the deadline

A few practical moves before April 12, 2026:

1. Pull composition data for every essential oil and fragrance blend currently in your active formulas.
2. Calculate each named allergen's real concentration in the finished product, not just in the raw oil.
3. Flag anything crossing threshold and get ready to add it to your ingredient declaration.
4. Remember List 2, the expanded allergen set, becomes mandatory a few months later on August 1, 2026, so this isn't a one-time fix, it's worth building the habit now.

This kind of threshold math, oil percentage times allergen fraction times use rate, is exactly the tedious multiplication that's easy to get wrong by hand across a whole product line. Cosmetic Comply runs these calculations automatically when you submit your formula, matching each aromatic constituent to its INCI name and flagging anything near or over the List 1 and List 2 thresholds before it becomes a filing problem.