Phenoxyethanol Preservative Limits Under Canada's Hotlist

Ask ten indie formulators what their go-to preservative is and phenoxyethanol comes up more than almost anything else, usually paired with a chelator or a second preservative for broad spectrum coverage. It is popular for good reason: broad efficacy, decent stability across a range of pH values, and wide regulatory acceptance. But "widely accepted" is not the same as "unlimited," and that distinction matters a lot once you sit down to file.

The basics

Phenoxyethanol's INCI name is, conveniently, exactly what you'd expect: Phenoxyethanol. Its CAS registry number is 122-99-6. Functionally, it works as a preservative, meaning its whole job is inhibiting microbial growth in your finished product over its shelf life, protecting both the product and the end user from contamination.

Detail	Value
INCI name	Phenoxyethanol
CAS number	122-99-6
Typical function	Preservative
Regulatory status	Restricted, with a maximum permitted concentration on Canada's Hotlist

Why the Hotlist entry exists

The Cosmetic Ingredient Hotlist is Health Canada's living reference of substances that are either prohibited outright or restricted to specific concentrations, product types, or conditions of use in cosmetics. Phenoxyethanol sits in the restricted category, meaning it is permitted, but only up to a maximum concentration that the Hotlist specifies. This is a common pattern for effective preservatives: broadly useful, but with a ceiling designed to keep exposure within a margin of safety even across leave-on and rinse-off products used daily.

Because Hotlist entries are reviewed and can be updated, always check the current Hotlist at the time you formulate and file, rather than relying on a percentage you remember from a past project or from a supplier's older technical bulletin. Supplier documentation can lag behind regulatory updates.

How the limit should shape your CNF range

Once you know phenoxyethanol has a maximum permitted concentration on the Hotlist, that number becomes the ceiling for whatever concentration range you declare on your Cosmetic Notification Form, not just a target to aim near.

A few practical points:

• If your formula targets a concentration comfortably below the Hotlist maximum, declare a bracket that reflects your real formula, not one that stretches up toward the legal ceiling unnecessarily.
• If your manufacturing process has any batch-to-batch variability, make sure your declared upper bracket bound, plus that variability, still lands under the Hotlist maximum with real margin. Declaring a bracket whose top edge sits exactly at the legal limit leaves zero room for a slightly over-dosed batch.
• If you are blending phenoxyethanol with another preservative, such as a common ethylhexylglycerin pairing used to boost efficacy at a lower phenoxyethanol load, each ingredient still needs its own accurate concentration and its own Hotlist check. A blend product name from your supplier does not exempt either component from individual review.

Watch for it hiding inside supplier blends

Phenoxyethanol rarely shows up alone from a supplier. It is frequently sold pre-blended with a co-preservative or a solubilizer under a trade name like "Preservative Eco" or similar branded blend names. When that happens, the blend's INCI declaration will list phenoxyethanol as one of its components at a certain percentage of the blend itself. To get phenoxyethanol's true concentration in your finished product, multiply the blend's use level in your formula by phenoxyethanol's percentage within that blend.

For example, if a preservative blend is used at 1 percent of your total formula, and phenoxyethanol makes up 80 percent of that blend, phenoxyethanol's real concentration in your finished product is 0.8 percent, not 1 percent. That 0.8 percent is the number that needs to be checked against the Hotlist maximum and the number that belongs on your CNF, not the blend's overall use level.

A quick gut check before you file

Before submitting, run through this short list:

1. Have you confirmed phenoxyethanol's current Hotlist maximum concentration directly from Health Canada's published list?
2. Have you calculated its true concentration in the finished product, accounting for any blend dilution?
3. Does your declared CNF bracket stay safely under that maximum, including realistic batch variation?
4. Is phenoxyethanol listed under its correct INCI name, separate from any co-ingredients in the same blend?

Getting this wrong is rarely a matter of bad intent. It is almost always a math or documentation gap, someone trusting a blend's trade name percentage instead of tracing it back to the actual preservative concentration. This is one of the exact calculations Cosmetic Comply automates when you upload a formula: it expands supplier blends into their true components, carries the percentages through, and checks each one against the current Hotlist before a human reviewer signs off on the filing.