Fragrance Allergen List 2 and the August 1 2026 Date

If you filed your CNF updates for List 1 fragrance allergens back in the spring and thought you were done for the year, there is a second date on the calendar. August 1, 2026 brings List 2 into mandatory effect, and it is worth treating as a distinct project rather than an extension of the same work.

Two lists, two dates, same underlying idea

Canada's fragrance allergen disclosure rolled out in two stages. List 1, the original fragrance allergen set, became mandatory on the Cosmetic Notification Form and the product label on April 12, 2026. List 2, an expanded set aligned with international allergen lists, becomes mandatory on August 1, 2026. Both lists work on the same basic mechanism: certain named allergens, when present above a defined threshold, need to be individually declared rather than folded anonymously into a generic "Parfum" or "Fragrance" listing.

The thresholds are the same across both lists:

Product type	Disclosure threshold
Leave-on cosmetics	Above 0.001% (10 ppm)
Rinse-off cosmetics	Above 0.01% (100 ppm)

Why List 2 catches more people off guard

List 1 covers allergens that many makers had already heard of, since names like Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin show up regularly in cosmetic chemistry conversations and appear naturally in a wide range of common essential oils. Makers using lavender, citrus oils, or rose-adjacent botanicals were already somewhat primed to expect at least some of these names to matter.

List 2 is described as an expanded set aligned with international lists, meaning it broadens the roster of specifically named allergens beyond that original, more familiar group. The practical effect is that a formula which cleared List 1 review without needing much individual declaration might still have allergens on List 2 present above threshold that need addressing separately. Do not assume that because you handled List 1 in the spring, your product is fully covered for August.

What to actually do before August 1

Treat this as a full re-check of your fragrance and essential oil ingredients, not a quick glance:

1. Pull the allergen declaration from every fragrance house and essential oil supplier you use. If you only asked for a List 1 breakdown earlier in the year, go back and ask specifically whether their declaration also covers List 2 allergens.
2. Recalculate concentrations for the finished product, not just the blend. Multiply each allergen's percentage within the fragrance or essential oil by that ingredient's use level in your formula, the same way you would for any supplier blend.
3. Compare against the correct threshold for your product type. Leave-on and rinse-off have different thresholds, and it is common for a maker to sell both a lotion and a body wash using the same fragrance blend at different use levels, requiring two separate checks.
4. File an amendment for any product where a List 2 allergen crosses threshold and was not already individually declared. Since a formula change is not what triggered this, it is the disclosure requirement that changed, but the mechanism is still an amendment to bring your existing notification and label into compliance.
5. Update your label artwork ahead of the deadline, not on it. Label reprints and packaging changes take lead time, and August 1 is when the requirement becomes mandatory, not when the paperwork process should start.

Essential-oil-forward brands have more work here, not less

If your brand's whole identity is built around essential oils rather than synthetic fragrance, it is tempting to assume you are in a better position because "it's natural." The allergen rules do not distinguish between natural and synthetic sources. Limonene from cold-pressed orange oil counts the same as Limonene from a synthetic fragrance compound. In fact, essential oils can carry meaningfully higher natural concentrations of these allergens than a synthetic fragrance engineered to a target scent profile, so brands leaning heavily on essential oils often have more individual allergens crossing threshold, not fewer.

Building a standing process rather than a one-time scramble

Since fragrance suppliers occasionally reformulate blends, and since you may add new scents to your line after August 1 anyway, it is worth building allergen declaration collection into your standard new-ingredient intake process going forward, rather than treating List 1 and List 2 as the only two moments this matters. Every new fragrance or essential oil supplier relationship should come with an allergen declaration request as a standard step, the same way you would ask for an SDS or a certificate of analysis.

Cosmetic Comply's screening carries this calculation through automatically once you enter your fragrance supplier's allergen declaration and your use level, flagging which allergens cross the leave-on or rinse-off threshold under both List 1 and List 2, so the August 1 date does not require a separate manual audit of every product in your line.