A Wholesale Buyer Wants Fragrance Allergen Disclosure

If you've gotten an email from a boutique or a wellness retailer asking for a "fragrance allergen breakdown" before they'll carry your candles or your lotion, you're not being singled out. Buyers are getting ahead of this on their own, partly because Canada's fragrance allergen labeling requirement has a real date attached to it, and retailers don't want a shelf full of product that needs relabeling right after they've bought it in.

The date the buyer is probably thinking about

List 1, the original set of fragrance allergens that Health Canada requires on the Cosmetic Notification Form and eventually on the label, becomes mandatory on April 12, 2026. A second, expanded set, List 2, aligned with broader international allergen lists, becomes mandatory later, on August 1, 2026. If a buyer mentions a date, it's almost certainly one of these two, and it's worth confirming which one they mean because the two lists aren't identical in scope.

Buyers who stock imported or larger brands have often already seen this requirement play out in the EU or elsewhere, where fragrance allergen disclosure has existed for longer. That's usually why they're asking early. They've been through a relabeling scramble before and don't want a repeat.

What actually triggers disclosure

You don't have to disclose every trace compound in your fragrance oil. The requirement is threshold-based:

• Leave-on products: disclosure required above 0.001% (10 ppm) of the allergen in the finished product
• Rinse-off products: disclosure required above 0.01% (100 ppm) of the allergen in the finished product

That's a meaningfully lower bar for leave-on products, which makes sense given the longer skin contact time. A body lotion and a shampoo with the exact same fragrance oil at the exact same use level can land on different sides of the disclosure line for the same allergen, purely because one rinses off and one doesn't.

The allergens most likely to show up

Common ones that show up in natural and synthetic fragrance alike include Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin. This list is not exhaustive, but it covers the ones that appear constantly in essential oils, so if your fragrance is naturally derived, don't assume you're exempt just because you didn't buy a "fragrance chemical." Citrus oils are loaded with Limonene. Many florals carry Linalool and Geraniol. Cinnamon and tonka-adjacent notes bring Coumarin along with them.

Getting the numbers a buyer will accept

A serious wholesale buyer wants more than "our fragrance is allergen-free" (which is very unlikely to be literally true) or a vague "we comply with regulations." What actually satisfies them:

1. Your fragrance supplier's allergen declaration. Reputable fragrance houses provide a breakdown of which allergens are present in their oil and at what percentage. Ask for this document specifically if you haven't already, it's usually a one-page IFRA-style disclosure.
2. Your own math carrying that through to the finished product. If your fragrance oil is used at 1% of the formula and the supplier declares 2% Linalool content in the oil itself, your finished-product concentration is 1% x 2% = 0.02%, which is above both the leave-on and rinse-off thresholds.
3. A clear statement of which list, or lists, you've checked against, since some buyers will specifically want to know you're prepared for both List 1 and List 2, even though only List 1 is mandatory first.

How to respond without overcommitting

It's fine to tell a buyer plainly where you are: "we've identified the allergens present from our fragrance supplier's declaration, we've calculated finished-product concentrations, and we're on track to have List 1 disclosure on our label ahead of the April 2026 requirement." That's a specific, credible answer. Don't promise a finished relabel date you haven't actually scheduled with your label printer, and don't claim an allergen-free fragrance unless your supplier's own declaration says so in writing.

If you genuinely haven't done this math yet, say that too, and give a realistic timeline. Buyers who ask this question tend to respect a maker who has a plan more than one who claims to already be finished.

Cosmetic Comply carries fragrance allergen percentages through the same ingredient math it uses for everything else, so when a supplier's allergen declaration goes in, the finished-product concentration and the threshold comparison come out the other side without you doing it by hand for every SKU, which is genuinely useful once a buyer starts asking for this across your whole product line rather than one item.