Selling Just 20 Bars a Month Still Means CNF Duties

Someone selling 20 bars a month out of a farmers market table asked me recently whether that volume was even worth notifying, since it felt too small to be on anyone's radar. It's a completely reasonable question to have, and the answer surprises a lot of makers: volume has nothing to do with it.

There is no size exemption in the Cosmetic Regulations

Health Canada's Cosmetic Regulations, made under the Food and Drugs Act, don't scale the notification requirement by units sold, revenue, or how many people you sell to. If your bar makes a cosmetic claim, whether it's "moisturizing," "gentle on sensitive skin," or "softens and smooths," it's a cosmetic under the law, and the Cosmetic Notification Form obligation attaches the same way whether you sold 20 bars or 20,000.

The 10-day clock is the same too. The CNF is due within 10 days of first sale, and "first sale" means the first time the product reaches a consumer, not the first time you hit some revenue milestone. Selling at a single craft fair table counts as first sale.

Why this feels counterintuitive

Most regulatory frameworks people encounter in daily life do scale with size. Food service inspections, employment law, tax filing thresholds, a lot of that has size cutoffs built in. Cosmetics notification doesn't work that way in Canada, largely because the CNF isn't a burden calibrated to business risk. It's a database entry that lets Health Canada see what's being sold and pull records fast if there's ever a safety concern. A tiny batch business selling an unsafe or mislabeled product is exactly the kind of gap that notification is meant to close, so there's no logical reason to carve out small sellers.

What "cosmetic claim" actually triggers this

This is where it's worth being precise, because true soap gets treated differently:

• A bar sold purely as soap with a cleansing claim (alkali salt of a fatty acid, marketed just as soap) can fall outside cosmetic regulation entirely
• The moment you add any cosmetic claim, moisturizing, anti-aging, softening, deodorizing beyond basic cleansing, it becomes a cosmetic and needs the CNF

Most handmade soap makers add glycerin, shea butter, or oils specifically to market a moisturizing benefit, and that marketing choice is what pulls the product into cosmetic territory. If your label or your Etsy listing says "gentle and moisturizing," you've made the claim that matters.

What the filing actually asks for

The CNF isn't a pre-market approval process, so you're not waiting for a green light before you can sell. You're filing:

• Your business and product information
• Every ingredient by INCI name, with concentration or a concentration range
• Confirmation the formula doesn't run afoul of the Cosmetic Ingredient Hotlist's prohibited and restricted substances

Once submitted through the Cosmetic Notification System, you get a Cosmetic Notification (CN) number back. If you change the formula later, that's an amendment. If you stop selling the product, that's a discontinuation filing.

What small-batch makers get wrong most often

• Assuming a hobby-level Etsy shop is invisible to regulators, when in practice complaints, retailer requests, or a customer reaction can surface a filing gap fast
• Waiting until sales pick up to "make it official," when the 10-day window started at your very first sale
• Not tracking INCI names and percentages from day one, which makes filing much harder to do accurately once you've been selling for months without records

If you're at the 20-bars-a-month stage, the honest move is to file now rather than treat it as a someday task. Cosmetic Comply is built for exactly this kind of small maker, taking your ingredient list, mapping it to INCI and CAS, screening it against the Hotlist, and filing the CNF once a reviewer checks it, so getting compliant doesn't require the same overhead as a much bigger operation.