List 1 and List 2 Fragrance Allergens: The 2026 Deadlines

Two dates, two lists, and a lot of confusion out there about which one applies to your product right now. I've had makers ask me if they have until August to do anything about fragrance allergens at all, and that's not quite right. Let me lay out exactly what's happening and when.

Two lists, not one

Canada's fragrance allergen disclosure requirement rolls out in two tiers, and each tier has its own hard date.

List 1 is the original, longer-established fragrance allergen set. It becomes mandatory on the CNF and on the product label on April 12, 2026. If your product contains a List 1 allergen above the applicable threshold, this is the date by which your Cosmetic Notification Form and your physical label both need to reflect it.

List 2 is an expanded set of allergens, aligned with broader international allergen lists, and it becomes mandatory on August 1, 2026. This is a separate, later deadline, adding more allergens to the disclosure requirement rather than replacing List 1.

The practical result is that between April 12 and August 1, 2026, you're operating under List 1 requirements only. From August 1, 2026 onward, both lists apply, and your notification and label need to account for the full combined allergen set.

Why two dates instead of one

Splitting the rollout gives makers a defined runway to update formulas, notifications, and labels in stages rather than facing every new allergen requirement simultaneously. It also mirrors how these lists were developed, with List 1 reflecting a well-established core set of known fragrance allergens, and List 2 bringing Canada's requirements closer in line with expanded international allergen lists used elsewhere.

A simple timeline

Date	What happens
Before April 12, 2026	No mandatory fragrance allergen disclosure requirement yet in effect
April 12, 2026	List 1 allergens become mandatory on CNF and label
April 12 to August 1, 2026	List 1 only is mandatory; List 2 not yet required
August 1, 2026	List 2 allergens also become mandatory, alongside List 1

What actually triggers disclosure

Regardless of which list an allergen sits on, disclosure isn't automatic just because a fragrance is present. It's triggered by concentration:

• Above 0.001% (10 ppm) in leave-on products.
• Above 0.01% (100 ppm) in rinse-off products.

So a rinse-off shampoo can carry a meaningfully higher concentration of a given allergen before disclosure kicks in, compared to a leave-on lotion or perfume carrying the same allergen. This threshold difference is worth understanding on its own, separate from the list timing, since it determines whether a specific allergen in your specific formula needs to appear at all.

Common allergens worth knowing by name

Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin show up constantly across both lists, and they occur naturally in a huge range of essential oils, not just synthetic fragrance compounds. This catches natural and "essential oil only" brands off guard sometimes, since there's an assumption that natural fragrance sources are somehow exempt from allergen disclosure. They aren't. A lavender essential oil naturally containing Linalool triggers the same disclosure logic as a synthetic fragrance compound containing it.

What to do before each date hits

1. Get your fragrance and essential oil suppliers to provide a full allergen breakdown for anything you use, not just a general "contains natural allergens" note.
2. Calculate your actual in-product concentration for each allergen present, accounting for your use level of the fragrance or essential oil blend, not just the blend's own composition.
3. Compare each calculated concentration against the applicable leave-on or rinse-off threshold.
4. Update your CNF and label plan against the correct date, List 1 items by April 12, 2026, and the full List 1 plus List 2 set by August 1, 2026.

Since allergen lists and thresholds are the kind of regulatory detail that can be refined as the dates approach, it's worth checking Health Canada's current guidance directly as you get closer to filing, rather than relying solely on a snapshot from today.

Cosmetic Comply builds allergen threshold checking directly into its ingredient screening, tracking supplier blend concentrations through to the finished product so you can see, ingredient by ingredient, whether you're above a disclosure threshold well before either 2026 deadline arrives.