How to Get an Allergen Declaration From Your Supplier

You email your fragrance supplier asking for an allergen declaration and get back a one-line PDF that says "complies with applicable regulations." That's not a declaration, that's a reassurance, and it won't hold up when you actually need to fill in the specific allergen concentrations on a notification. Here's what to ask for instead, and why most first responses from suppliers fall short.

Why you need this at all

Fragrance oils and essential oils are blends, sometimes dozens of components, and several of those components are recognized fragrance allergens: Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin among the most common, occurring naturally in a wide range of essential oils rather than being unusual additives. Canada's disclosure rules require these to be identified once they cross a concentration threshold, above 0.001% (10 ppm) in leave-on products and above 0.01% (100 ppm) in rinse-off products. You can't calculate whether your finished product crosses those thresholds unless you know the allergen composition of the fragrance blend itself, and that information lives with your supplier, not with you.

Two important dates to keep in mind while you're building this habit: List 1 becomes mandatory on the CNF and label on April 12, 2026, and List 2, the expanded set, becomes mandatory August 1, 2026. If your supplier relationship and documentation process aren't already handling this, now is the time to fix that, not closer to either deadline.

What to actually ask for

A useful request to your supplier is specific, not general. Instead of "do you comply with allergen regulations," ask for:

1. A full breakdown of allergen content in the specific fragrance oil or blend you purchase, listed by INCI name (or CAS number) and percentage within that blend.
2. Confirmation of which recognized allergens, from the current disclosure lists, are present, even at low levels, since low doesn't mean absent from the requirement, it just changes the concentration math.
3. The document dated and tied to a specific batch or formulation version of the fragrance, since suppliers do reformulate blends over time without always renaming the product.
4. A statement of whether the declaration covers List 1, List 2, or both, since a supplier who only tracks the older, narrower list may be missing components that matter under the expanded set.

What a genuinely useful declaration looks like

A compliant, usable allergen declaration document typically includes:

Element	Why it matters
Product name and batch or version reference	Ties the declaration to the exact material you're using
List of allergens present, by INCI name	Lets you match against Canada's current disclosure lists
Percentage of each allergen within the blend	Needed to calculate real concentration in your finished product
Date of issue	Confirms the declaration reflects a current formulation, not an outdated one
Supplier contact for verification	Useful if a regulator or reviewer ever asks follow-up questions

If what you receive is missing the percentage column, it's not usable for a real filing. You can know an allergen is "present" without knowing whether it's present at a level that even crosses the threshold in your finished product, and that number is the whole point.

Doing the math once you have it

Say your fragrance oil declaration shows Linalool at 3% within the blend, and you use that fragrance oil at 1% in your leave-on lotion. The real concentration of Linalool in your finished product is 0.03% (3% times 1%), which is well above the 0.001% leave-on threshold and needs to be declared. This multiplication step, blend percentage times use level, is the same logic that applies to any supplier blend, not just fragrance, but it's especially easy to get wrong with fragrance oils because the allergen percentages inside them are often small numbers that feel negligible until you see them clear a threshold.

When your supplier can't or won't provide this

Some smaller or overseas fragrance suppliers genuinely don't track allergen composition in a format you can use, either because their own documentation is thin or because they haven't needed to provide it for other markets they sell into. If that's the situation, you have a few options: ask if they can commission or share a gas chromatography analysis, look for a different supplier who already serves customers in allergen-disclosure markets and has the paperwork built, or, as a last resort, have the specific fragrance oil tested independently. Formulating with an undocumented fragrance blend and hoping it's fine isn't a real option once List 1 becomes mandatory, since you'd be filing a notification you can't actually substantiate.

Keeping this organized as you scale

Once you have a real declaration for a fragrance oil, keep it filed against that specific ingredient the same way you'd keep an SDS, and revisit it if your supplier ever mentions a reformulation, even a minor one. Cosmetic Comply keeps supplier blend data, including fragrance allergen breakdowns, attached to each ingredient in your formula, so the concentration math and threshold checks happen automatically as part of screening, and the allergen declaration you tracked down becomes something that's actually usable at filing time rather than a PDF sitting in an email folder.