The Full List 1 Fragrance Allergen Breakdown

April 12, 2026 is not far off, and if your fragrance ingredient list has not been checked against List 1 yet, this is the reference to work from before that deadline is closer than comfortable.

What List 1 is and why it exists

List 1 refers to the original set of fragrance allergens that becomes mandatory to disclose, both on the Cosmetic Notification Form and on the product label, starting April 12, 2026. A second, expanded set aligned with international allergen lists, referred to as List 2, follows on August 1, 2026. The staggered rollout gives makers a runway, but it also means two separate deadlines to track for two separate (though overlapping in spirit) sets of substances.

These allergens are not exotic synthetic additives you would only find in a lab-formulated fragrance. Most of them occur naturally in common essential oils, which is exactly why makers who think of themselves as "all natural" or "essential-oil-only" are not exempt from this disclosure. A lavender essential oil, for instance, naturally contains linalool. A citrus essential oil naturally contains limonene. Disclosure applies regardless of whether the allergen arrived via a synthetic fragrance compound or a bottle of pure essential oil from a farm you trust.

Commonly named List 1 substances

The allergens most frequently referenced as part of this original disclosure set include:

Allergen	Naturally occurs in	Typical product context
Limonene	Citrus oils (orange, lemon, bergamot)	Fragrances, cleansing products, many "citrus" scented items
Linalool	Lavender, coriander, many floral oils	Fragrances, lotions, soaps
Citronellol	Rose oil, geranium oil, citronella	Fragrances, floral-scented products
Geraniol	Rose oil, geranium oil, palmarosa	Fragrances, floral-scented products
Eugenol	Clove oil, cinnamon leaf oil	Fragrances, spice-scented products
Coumarin	Tonka bean, some cinnamon and lavender types	Fragrances, sweet or vanilla-adjacent scents

This is a reference to work from, not an exhaustive substitute for the current official list. Because the compliance date is approaching and the scope of List 1 versus List 2 is a live regulatory detail, verify the complete and current list directly against Health Canada's published guidance before finalizing your own disclosure, particularly if your formula includes fragrance components beyond the commonly cited ones above.

The two thresholds that decide if you disclose

Disclosure is not triggered by presence alone, it is triggered by concentration crossing a threshold, and the threshold depends on how the product is used:

• Leave-on products (lotions, creams, perfumes, anything not rinsed off): disclosure required above 0.001 percent, which is 10 parts per million
• Rinse-off products (soaps, shampoos, cleansers): disclosure required above 0.01 percent, which is 100 parts per million

Leave-on products get the stricter threshold because the allergen stays in contact with skin longer. Ten parts per million sounds vanishingly small, and it is, which is why the expansion-of-blends step matters so much here. A fragrance oil that is 5 percent of your formula and contains even a small internal percentage of linalool can easily cross that leave-on threshold once you multiply it through.

Working through your own formula

For each fragrance-contributing ingredient in your formula, whether that is a commercial fragrance blend, a single essential oil, or an essential oil blend you made yourself:

1. Get the supplier's documentation on allergen content, or if you are blending essential oils yourself, research the known allergen components of each oil
2. Calculate each allergen's real concentration in your finished product by multiplying the fragrance ingredient's percentage in your formula by the allergen's percentage within that ingredient
3. Compare against the leave-on or rinse-off threshold depending on your product type
4. If it crosses the threshold, that allergen needs to appear on your CNF and eventually your label

Two deadlines, one habit

Since List 2 lands four months after List 1, on August 1, 2026, it is worth doing this allergen-mapping exercise once, thoroughly, rather than twice. Build a spreadsheet now that tracks every allergen-relevant component across your product line, and you will be in a much better position to add List 2 substances to the same sheet later rather than starting from scratch.

Cosmetic Comply's screening checks fragrance components against allergen thresholds as part of the ingredient matching step, flagging what crosses the leave-on or rinse-off line before your notification goes in, so this deadline does not have to mean a frantic spreadsheet audit in March.