Notifying a Perfume or Eau de Toilette Step by Step

Perfume looks deceptively simple to file. Three or four ingredients on the surface: alcohol, water, fragrance oil, maybe a fixative. But that fragrance oil is doing almost all the regulatory work in the formula, and it's usually the part makers understand least when they sit down to fill out a Cosmetic Notification Form.

Start by naming what "perfume" actually means on the label

Eau de parfum, eau de toilette, and eau de cologne aren't just marketing tiers, they roughly correspond to the concentration of fragrance oil in the alcohol base, from richer and more concentrated down to lighter. For notification purposes, what matters isn't the marketing name itself, it's the actual composition you're filing: the alcohol denat or Aqua and Alcohol Denat base, and the Parfum (or Fragrance) entry with its real concentration in the finished product.

If you formulate multiple strengths from the same fragrance oil, an eau de parfum and a lighter eau de toilette version, treat them as what they are on paper: different concentrations of the same core ingredients, each needing its own accurate percentage entered on its own notification, not one filing reused for both.

The fragrance oil is not one ingredient, it's dozens

This is the part that catches people off guard. A single fragrance oil, sold to you by a supplier as one line item, is itself a blend, often dozens of aroma chemicals and naturally derived materials. For a Cosmetic Notification Form, you generally list "Parfum" as the ingredient with its overall concentration in the product. But underneath that single label declaration, the individual components, especially the ones classified as fragrance allergens, need to be tracked because of separate disclosure rules that apply once they cross a concentration threshold.

Ask your fragrance supplier for the full composition breakdown, not just a general accord description. You need to know which recognized allergens are present and at what percentage within the fragrance oil itself, so you can calculate their real concentration in your finished perfume.

Fragrance allergens in a genuinely concentrated product

Perfume is the category where allergen concentration math matters most, because fragrance oil is present at a real, substantial percentage rather than the trace levels typical of a lightly scented lotion. Canada's fragrance allergen disclosure applies once specific allergens exceed defined thresholds, above 0.001% (10 ppm) in leave-on products, which a perfume clearly is. Common allergens like Limonene, Linalool, Citronellol, Geraniol, and Eugenol show up naturally in a huge range of essential oils and aroma chemicals, so it's genuinely likely that several of them will be present in any fragrance oil at levels well above that leave-on threshold.

Two dates matter here and they're worth marking on a calendar rather than trying to remember: 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, becomes mandatory August 1, 2026. If you're filing or refiling a perfume around either of those dates, build the allergen declaration into the filing from the start rather than treating it as an afterthought, since a perfume is exactly the product type most likely to trip multiple allergen thresholds at once.

A simplified example filing

INCI entry	Approx. concentration in finished perfume	Filing note
Alcohol Denat.	~80%	Base carrier
Aqua	~5%	Diluent
Parfum	~15%	Declared as single entry
Limonene (from Parfum)	~0.3% (from allergen breakdown)	Above leave-on threshold, declare per current allergen list requirements
Linalool (from Parfum)	~0.2% (from allergen breakdown)	Above leave-on threshold, declare per current allergen list requirements

The percentages here are illustrative, not a template to copy. Every fragrance oil has a different internal composition, and getting your specific supplier's breakdown is non-negotiable if you want an accurate filing rather than a guessed one.

Don't forget the alcohol base itself

Alcohol Denat. is generally uncontroversial from a restricted-ingredient standpoint, but it's worth double-checking the specific denaturant used, since formulations vary by supplier and region, and confirming it against the current Cosmetic Ingredient Hotlist along with everything else in the formula rather than assuming it's automatically fine because it's common.

Filing within the window

Once your perfume is ready for its first sale in Canada, the Cosmetic Notification Form is due within 10 days, filed through the Cosmetic Notification System, after which you'll receive a Cosmetic Notification number. If you tweak the fragrance oil concentration later, or reformulate with a different accord, that's an amendment, not a brand new product, as long as the base product identity stays the same.

Given how much of a perfume's regulatory profile lives inside a single "Parfum" line item, this is a category where Cosmetic Comply's approach of expanding supplier blends into real percentages earns its keep. It takes your fragrance supplier's breakdown, calculates true finished-product concentrations for each allergen, screens the whole formula against the Hotlist, and carries the allergen declaration through to filing once a compliance reviewer has checked it.