List 2 Fragrance Allergens and the August 2026 Soap Deadline

If you already sorted out List 1 fragrance allergen disclosure for your April deadline, don't relax yet. List 2 lands August 1, 2026, and it's a genuinely different piece of work, not a formality tacked onto what you already did.

Quick recap on where things stand

List 1, the original fragrance allergen set, becomes mandatory on both the Cosmetic Notification Form and the product label as of April 12, 2026. If your soap is on the market by then, you should already have gone through your fragrance and essential oil blends checking for List 1 allergens above the disclosure thresholds, above 0.001% (10 ppm) for leave-on products and above 0.01% (100 ppm) for rinse-off products, which for most soap is the relevant threshold since soap is generally a rinse-off product.

List 2 is a separate, expanded set of allergens aligned with international lists, and it becomes mandatory on the same disclosure basis, CNF and label, starting August 1, 2026. It's not replacing List 1, it's adding to it. Come August, you need both lists checked and both sets of triggered allergens disclosed.

Why this specifically matters for soap

Soap makers rely heavily on essential oils, and essential oils are complicated blends of dozens of naturally occurring constituents, several of which are recognized fragrance allergens. Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin are common examples, and they occur naturally in many essential oils rather than being something added separately. A lavender essential oil isn't "lavender oil plus linalool," it's an oil where linalool is naturally one of dozens of constituent compounds already present.

This means soap makers can't just check the essential oil's name against an allergen list. You need to know, or get from your supplier, the actual percentage of each allergen constituent within the essential oil itself, then work out what that becomes once the oil is used at your soap's fragrance load.

Working through the actual math

The calculation has two steps:

1. Find the concentration of the allergen constituent within the essential oil (your supplier's certificate of analysis or technical data sheet should have this, expressed as a percentage of the oil).
2. Multiply that percentage by your essential oil's use rate in the finished soap recipe.

If an essential oil is documented at 3% linalool content and you're using that oil at a 3% fragrance load in your soap recipe, the linalool concentration in the finished bar works out to a small fraction of a percent. Whether that fraction crosses the rinse-off threshold of 0.01% (100 ppm) is exactly the number you need before deciding whether it needs disclosure.

What changes with List 2 specifically

Because List 2 expands the set of named allergens, essential oils that came back clean under List 1 review might still have constituents that fall under List 2's expanded roster. The practical implication:

• Redo your allergen constituent check on every essential oil blend, this time against the full List 2 roster, not just List 1
• Update your supplier documentation requests if your current certificates of analysis only broke out List 1 allergens
• Revisit soaps that passed List 1 review with no disclosures required, since List 2 could change that outcome for the same recipe

Milestone	Date	What becomes mandatory
List 1	April 12, 2026	Original fragrance allergen set, CNF and label
List 2	August 1, 2026	Expanded allergen set, CNF and label

Getting ahead of the August deadline

The soap makers who find this manageable are the ones who go blend by blend now, essential oil by essential oil, rather than waiting until late July to start pulling certificates of analysis from suppliers. If you've got several fragrance blends across a product line, that's genuinely a few hours of work per blend once you have the supplier data in hand.

This constituent-level allergen math, expanding an essential oil into its named allergens and carrying the percentages through to your finished soap's concentration, is exactly the kind of multi-step calculation Cosmetic Comply's ingredient matching is built to handle automatically as part of preparing a Canadian notification, so you're not doing List 1 and List 2 spreadsheets by hand for every blend in your lineup.