Putting Fragrance Allergens Into Your Ingredient List

You have "Parfum" sitting near the bottom of your ingredient list, doing its job as a catch-all for the fragrance blend. Then someone tells you that starting April 12, 2026, certain allergens inside that blend need to be called out by name on the label too, separately from the word "Parfum" itself. So where do they actually go? Above it? Below it? Instead of it? This trips people up because it looks like a contradiction: you are simultaneously hiding the fragrance behind one word and naming specific pieces of it.

It is not a contradiction. It is two different disclosure jobs happening at once.

Two jobs, one ingredient list

"Parfum" (or "Fragrance") represents the proprietary fragrance blend as a whole. Regulators generally do not require the full formula of a fragrance compound to be disclosed, since that is treated as the fragrance house's trade secret. What has changed, and continues to change, is a separate requirement layered on top: specific allergenic components within that blend need to be named individually when they are present above a defined threshold, regardless of the fact that the blend as a whole is still listed generically as "Parfum."

So your list ends up doing both things: "Parfum" stays in as its own entry, and the individual allergens it contains, when they cross the disclosure threshold, get their own separate entries using their own INCI names, like any other named ingredient.

Where allergens sit in list order

Ingredient lists are ordered generally by descending concentration, and named fragrance allergens slot into that same ordering logic based on their own concentration in the finished product, not based on where "Parfum" happens to sit. In practice this means:

• If Linalool is present at a concentration that would place it, say, fourth on the list by weight, it appears in that fourth position, named as Linalool, using its own line.
• "Parfum" itself continues to occupy its own position, reflecting the fragrance blend's total concentration.
• The allergen entry is additional information about what's inside the blend. It does not replace "Parfum," and it is not nested underneath it or bracketed to it, it just sits in the list according to its own concentration like any other ingredient.

This is the part that surprises people the most: a named allergen and the generic "Parfum" entry can both appear on the same list without one canceling the other out, because they are answering different questions. "Parfum" answers "is there a fragrance blend in this product." The named allergen answers "does that blend contain this specific substance above the threshold that requires disclosure."

The thresholds that trigger disclosure

In Canada, the trigger points are concentration-based and differ by product type:

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

A lotion left on the skin has a much lower bar for triggering disclosure than a rinse-off shampoo, which makes sense given the difference in skin contact time.

Two rounds, two dates

Canada is rolling this in through two lists on two separate dates. List 1, the original fragrance allergen set, becomes mandatory on the CNF and the label on April 12, 2026. List 2, an expanded set aligned with international lists, follows on August 1, 2026. If you file a CNF now expecting to only ever deal with List 1, plan ahead, because List 2 is coming later the same year and will expand what needs disclosing.

Common allergens you'll actually see

Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin show up constantly because they occur naturally in a huge range of essential oils, not just synthetic fragrance compounds. A "natural" or "essential oil based" fragrance claim does not exempt you from this. If your lavender essential oil brings Linalool along at a level above threshold, it needs naming, full stop, regardless of how you're marketing the product.

Getting the concentration right in the first place

The tricky math usually is not the label itself, it is figuring out the actual concentration of each allergen buried inside a supplier's fragrance blend. If your fragrance house tells you the blend is used at 1% in your formula and that blend is 2% Linalool by composition, your actual finished-product concentration of Linalool is 0.02%, not 2%. Get that multiplication wrong and you either under-disclose an allergen that should be named, or over-disclose one that doesn't need to be. This is exactly the kind of blend-expansion math that Cosmetic Comply automates when it processes a formula, carrying supplier blend percentages through to real finished-product concentrations and flagging what actually crosses each allergen threshold before you build your label.