Consultations on regulatory proposal for disclosure of fragrance allergens on cosmetic labels: Open until April 22, 2023

March 30, 2023 | Jaclyne Reive, Ralitsa Harding

Health Canada recently announced proposed changes to the Cosmetic Regulations (Canada) in connection with the disclosure of fragrance-based allergens on product labels. It has launched a consultation on this topic, inviting interested parties to provide comments on the proposed changes. The consultation is open to industry professionals, stakeholders, consumers, and the general public until April 22, 2023, with comments submitted through an online commenting feature.

The Cosmetic Regulations already require the disclosure of all ingredients on cosmetic labels but currently allow the use of the term “parfum” to indicate the presence of fragrance ingredients to avoid needing to disclose what could otherwise be a lengthy list of a mixture of fragrance ingredients. The proposed changes would require “contact” fragrance allergens to be disclosed within the list of ingredients on product labels, but would provide flexibility where cosmetics are sold in small packages by allowing disclosure of ingredients on the brand’s website. The proposal is meant to address the lack of information currently available on cosmetic labels for consumers who may be allergic or sensitive to specific fragrance ingredients to assist them in making safe and informed purchasing decisions. The proposal would also clarify terminology used in the Cosmetics Regulations such as “manufacturer” and “importer” in order to clarify their roles and responsibilities. It would also propose certain changes to cosmetic notification requirements, including requiring a cosmetic notification to be made in the event that the sale of a product is discontinued in Canada.

The proposed changes relating to the disclosure of fragrance allergens would come into effect two years following their introduction. In other words, there will be a two year transition period after the changes are approved, before the new disclosure requirements are enforced. All other proposed changes would come into effect six months after their approval.

To participate, interested parties can submit comments as an individual, an organization, or anonymously through the online commenting feature before the April 2023 deadline. Approved comments will be published on the Canada Gazette website after the comment period closes.

Should you have any questions regarding cosmetics labelling and compliance in Canada, please reach out to any member of Miller Thomson’s Marketing, Advertising and Product Compliance team.


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