What Changes for Your Labels on August 1 2026

If you already handled the April 12, 2026 fragrance allergen update for List 1, good, but don't file that project away and move on, because August 1, 2026 brings List 2, an expanded set of allergens aligned with international lists, and if you carry more than a handful of scented SKUs, this is worth planning as its own project rather than a quick follow-up.

Why List 2 is a bigger lift than List 1 for most brands

List 1 covered the original, more narrowly defined fragrance allergen set, the names most formulators already recognized: Limonene, Linalool, Citronellol, Geraniol, Eugenol, Coumarin among them. List 2 broadens that set considerably, aligning with international allergen lists that go beyond what List 1 covered. Practically, this means:

• More of your existing SKUs will likely trigger a disclosure requirement, simply because more named substances are now in scope, and essential oils and fragrance blends that cleared List 1 cleanly may still contain List 2 substances above threshold.
• Your fragrance suppliers need to re-run their allergen declarations against the expanded list, not just hand you the same certificate they gave you for the April deadline.
• Products that seemed "simple" on List 1 (say, a single-note fragrance with only one or two flagged constituents) may turn out to have several more List 2 constituents once the wider net is applied.

The thresholds don't change, only the substance list does

It's worth being precise about what's actually changing on August 1. The disclosure trigger concentrations stay the same:

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

What changes is which named substances count against those thresholds. A formula that was fully compliant on April 12 because its only flagged constituents were List 1 names could still need new label lines added on August 1 if any List 2 substances are present above threshold.

A realistic prep timeline for a multi-SKU brand

If you have, say, 15 or 20 scented SKUs across soaps, lotions, and serums, working backward from August 1 is more manageable than trying to do it all at once close to the deadline.

1. Now through early June: request updated allergen declarations from every fragrance and essential oil supplier, specifically covering the List 2 substances, not just List 1. Don't assume your existing April paperwork covers it.
2. June: run the concentration math for every SKU. Multiply each allergen's percentage within the fragrance or oil by your usage level, and compare each result against the leave-on or rinse-off threshold for that product type.
3. Early July: finalize which SKUs need new or additional label lines, and get updated artwork into production. Printed packaging lead times are usually the actual bottleneck here, not the compliance math.
4. Mid to late July: update your Cosmetic Notification Form filings to reflect the new allergen declarations, since the CNF needs to carry the same information as the label.
5. Before August 1: confirm new labeling is in place for anything manufactured or sold from that date forward.

Where brands tend to get caught out

The most common misstep is treating this as a label-only update and forgetting the CNF side. Your filing and your label are supposed to describe the same product consistently, and if List 2 substances now need disclosure, that applies to both, not just whichever one is easier to change quickly. A related misstep is assuming a fragrance blend that was fine in April is automatically fine in August, when in fact the entire point of List 2 is that it catches things List 1 didn't.

It's also worth double-checking your inventory situation. If you have pre-printed packaging stock manufactured before August 1 that doesn't reflect List 2 disclosures, it's worth understanding whether existing stock can still be sold or whether the deadline applies to sale date rather than manufacture date. That's exactly the kind of detail worth confirming directly with the current Health Canada guidance rather than assuming, since transition provisions for stock on hand can vary.

Making this manageable across a whole product line

Doing this ingredient by ingredient, SKU by SKU, by hand, across 15 or 20 products each with their own fragrance supplier, is exactly the kind of repetitive, error-prone task that benefits from a system rather than a spreadsheet you're maintaining alone. Cosmetic Comply takes your fragrance and essential oil percentages, expands supplier blends into their named allergen components, calculates the real finished-product concentration against the leave-on or rinse-off threshold, and flags exactly which SKUs need new label lines for List 2, before a reviewer confirms the result and you file the amendment. If you've got a scented product line of any real size, starting this now rather than in July gives you room to deal with packaging lead times without a scramble.