Prohibited & Restricted

How to Read a Hotlist Restriction With a Concentration Limit

Breaks a restricted Hotlist entry down line by line, covering the substance, permitted use, maximum concentration, and any required label wording.

Diane R.4 min read

The first time you open the Cosmetic Ingredient Hotlist looking for one specific ingredient, the entry format isn't immediately obvious. It's not just a name and a yes-or-no. A restricted entry usually packs several separate pieces of information into a few lines, and reading it correctly matters more than most makers assume.

The entry isn't one rule, it's several stacked together

A prohibited entry is simple: the substance can't be used in a cosmetic sold in Canada, full stop. A restricted entry is different. It's telling you the substance is allowed, but only under specific conditions, and those conditions typically stack together rather than standing alone. Miss one piece and you can be technically over the limit even if you thought you'd read the entry correctly.

Break a typical restricted entry into its component parts:

  • The substance itself, identified in a way that should map cleanly to an INCI name and, ideally, a CAS number, since that's what actually ties the Hotlist entry to what's in your formula.
  • The product type or category the restriction applies to. Some restrictions only bite for certain use categories, rinse-off versus leave-on being the most common split, or products intended for a specific body area.
  • The maximum permitted concentration, usually expressed as a percentage of the finished product.
  • Any additional conditions, such as a required label statement, a purity specification, or a restriction that only applies in combination with another ingredient.

Why the product type matters as much as the number

This is the part people skip past fastest and shouldn't. A concentration limit that applies to a rinse-off product doesn't necessarily transfer to a leave-on product using the same ingredient, and the reverse is just as true. Fragrance allergen disclosure follows exactly this pattern generally, with different thresholds for leave-on products (0.001%, or 10 ppm) versus rinse-off products (0.01%, or 100 ppm). A Hotlist restriction can carry the same kind of split logic, where the category your product falls into determines which number actually applies to you.

So before you even get to the percentage, confirm you've correctly identified what category your product sits in under that specific entry. A body wash and a body lotion can carry the same ingredient at the same raw concentration and still land on different sides of a restriction, because one rinses off and one doesn't.

Doing the math against your actual formula

The concentration limit in the Hotlist is a limit on the finished product, not on any single raw material you bought. That distinction matters most when the restricted substance arrives via a supplier blend rather than as something you weighed in directly.

Say a restriction caps a substance at a certain percentage of the finished product, and that substance is a component inside a fragrance blend you're using at 0.8% of your formula. If the substance makes up 5% of that blend's composition, its real concentration in your finished product is 0.8% × 5%, which comes out to 0.04%. That's the number that has to sit under the Hotlist limit, not the 0.8% blend usage rate and not some assumption based on the blend's trade name. This is exactly the kind of calculation that gets missed when a formula is documented by blend name only, without the underlying component breakdown.

An example structure, illustrated generically

Field What it tells you
Substance / INCI name What you're matching against your ingredient list
Product category scope Whether the limit applies to your specific product type (leave-on, rinse-off, or a narrower category)
Maximum concentration The ceiling for that substance in your finished product, after accounting for any blends
Label statement required Wording that must appear on your packaging if the substance is used, separate from the concentration question
Other conditions Purity requirements, combination restrictions, or anything entry-specific

Treat this as the shape of what to look for, not a substitute for reading the actual current entry. The Hotlist gets updated, and specific substances move between prohibited and restricted status or get new conditions attached, so always check the entry as it stands now rather than relying on something you read a year ago.

A habit worth building

Whenever a restricted ingredient shows up in your formula, don't stop at confirming the raw percentage looks fine. Confirm the product category applies to you, run the blend math if the ingredient arrives via a supplier mixture rather than direct addition, and check whether a label statement is required, since that's a separate obligation from the concentration limit and easy to miss entirely if you're only scanning for the percentage.

Cosmetic Comply screens every ingredient against the Hotlist automatically as part of a Canadian filing, including the blend math that turns a supplier's usage rate into the real finished-product concentration, and flags anything that needs a closer look with a confidence score before a real reviewer signs off.

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