Fragrance Allergen List 2 Concentrations Before August 2026

If you've already gotten your head around Canada's List 1 fragrance allergens ahead of the April 12, 2026 deadline, don't relax yet. List 2 lands a few months later, on August 1, 2026, and it's a genuinely bigger set of substances to check because it's aligned with broader international allergen lists rather than being the original, narrower Canadian set.

Two deadlines, two lists, one habit

Health Canada's approach here has been staged. List 1 is the original fragrance allergen set, and it becomes mandatory on both the Cosmetic Notification Form and the product label starting April 12, 2026. List 2 expands the scope significantly and becomes mandatory August 1, 2026. Practically, that means a formula that cleared your List 1 check in the spring still needs a second look before summer, because List 2 introduces additional named substances that weren't part of the first wave.

The thresholds themselves don't change between the two lists. Disclosure is still triggered above 0.001% (10 ppm) in leave-on products and above 0.01% (100 ppm) in rinse-off products. What changes is which substances you're checking for.

Why List 2 catches more formulas

List 2 aligns more closely with international fragrance allergen lists, which tend to be broader than the original Canadian List 1 set. In practice, that means ingredients and fragrance components that comfortably passed a List 1 check might still contain a List 2 substance at a concentration that clears the disclosure threshold. Essential oils are a common source of this, since many carry a range of naturally occurring constituents beyond just the handful of best-known names like Limonene and Linalool.

What to actually do before August

1. Get your fragrance and essential oil suppliers' full composition data again, this time asking specifically whether their documentation covers the expanded List 2 substances, not just the original List 1 set. Some suppliers updated their certificates as the List 2 deadline approached; others may not have, so ask directly rather than assuming.
2. Redo the concentration math for every fragrance-containing product, using the same multiplication approach as before: the supplier's declared percentage for each named substance, multiplied by your use rate of that fragrance or essential oil in the finished product.
3. Compare each result against the leave-on or rinse-off threshold, exactly as you did for List 1, since the thresholds themselves haven't moved.
4. Update your label copy and CNF filings for anything that newly crosses the line. A product that had no disclosed allergens under List 1 might need one or two named under List 2.

A simple way to track this

Keeping a running table per product makes this much less painful when a second list lands:

Product	Fragrance source	Named allergen	Supplier %	Use rate	Finished %	Threshold cleared?
Lavender soap	Lavender EO	Linalool	30%	1.5%	0.45%	Yes, rinse-off
Citrus lotion	Orange fragrance oil	Limonene	45%	0.8%	0.36%	Yes, leave-on

Once you have a table like this built for List 1, extending it to cover List 2 substances is mostly a matter of adding rows, not starting over.

Don't wait until July

The temptation is to treat August 1 the way a lot of people treat any deadline months away, as something to deal with later. But if List 2 checking reveals a formula needs reformulating, or a label needs new copy approved and reprinted, that takes real lead time. Doing this work now, while you still have runway, is a lot less stressful than doing it as a scramble in July.

Because these lists and thresholds can be updated, it's worth confirming the current, exact List 2 substance roster directly with Health Canada's published guidance rather than relying on secondhand summaries as the date approaches.

Cosmetic Comply keeps its allergen screening current against Health Canada's published lists and thresholds, and re-checks a formula automatically as those lists change, so a product that passed a screen in the spring gets flagged again if a new list introduces something relevant before you file or refile.