Health Canada has strengthened its oversight of cosmetics sold in Canada, with new requirements that affect foreign manufacturers and importers alike. While many compliance obligations have been in place for years, several key updates were recently introduced that make a Canadian presence and detailed traceability more important than ever.
At Progress Therapeutics, we help our clients stay ahead of these changes. Below, we break down what’s new—and what’s always been required—when importing cosmetic products into Canada.
New Cosmetic Regulations You Must Now Follow
1. Canadian Address Now Mandatory on CNFs
Health Canada has made new changes to the Cosmetic Notification Form (CNF) requirements, effective March 5, 2025, to strengthen regulatory oversight and product accountability in Canada. One of the most significant updates is that all CNFs must now include a valid Canadian address for either the manufacturer or the importer. This ensures there is a domestic point of contact responsible for each product on the market.
As a result of these new changes, foreign cosmetic companies can no longer submit CNFs on their own unless they have an office in Canada. They are now required to appoint a Canadian agent or importer of record. This step is critical to ensure compliance and uninterrupted market access. Progress Therapeutics fills this role for international brands, helping them meet all Health Canada obligations while streamlining the importation process.
2. Defined Roles in CNF Section 4
As mentioned above, Health Canada now requires a Canadian address on all CNFs—forcing foreign brands to appoint a local representative. In addition to that change, the updated Cosmetic Notification Form now requires full contact information for several distinct roles, rather than just a single point of contact.
Previously, companies often listed only the manufacturer or importer with limited detail. Under the new structure, the CNF must now include complete information for the:
- Manufacturer
- Importer
- Formulator or third-party
- Canadian Agent
- Label Contact
This shift improves traceability and ensures Health Canada can quickly reach the right party for any compliance, labeling, or safety issue. It also reinforces the importance of having a qualified Canadian partner to manage your cosmetic product’s entry and presence in the Canadian market.
3. Fragrance Allergen Labeling (Effective April 12, 2026)
Health Canada will require cosmetic products to disclose specific fragrance allergens on both product labels and the Cosmetic Notification Form (CNF) starting April 12, 2026. This applies if any of the designated allergens exceed 0.01% in rinse-off products or 0.001% in leave-on products.
Previously, terms like “parfum” or “fragrance” were used broadly, masking the presence of potentially irritating substances. The updated rule aligns with EU standards and enhances consumer protection by improving ingredient transparency.
For importers, this change means conducting a detailed review of fragrance components within each formula and ensuring product labels and CNFs are updated with any allergens that meet the threshold.
4. Revised CNF Format and Ingredient Definitions
Separately, Health Canada’s SOR/2024-63 amendment—effective October 9, 2024—modernizes how cosmetic product information is submitted through the Cosmetic Notification Form (CNF). This update introduces a more structured format, requiring clearer classification (e.g., rinse-off vs. leave-on) and more precise concentration data for all ingredients, not just allergens.
The new format emphasizes the use of INCI names and defined concentration ranges, reducing ambiguity in regulatory submissions and improving consistency across the industry.
Importers and manufacturers should begin updating internal formulation records and train relevant staff to meet the new formatting requirements well before the compliance deadline.
Longstanding Cosmetic Import Rules Still in Effect
1. CNF Submission Required Within 10 Days of First Sale
All cosmetic products sold in Canada must be reported to Health Canada through a CNF, which must be submitted within 10 days of first sale.
2. Re-Notification Requirements for Product Changes
If you make changes to your cosmetic product—including updates to ingredients, packaging, manufacturer details, or labeling—you must submit an updated CNF within 10 days. This also applies when a product is discontinued or a Canadian Agent is added post-March 2025.
3. Record-Keeping and Safety Documentation
Cosmetic importers and manufacturers must maintain comprehensive records that can be provided to Health Canada or CBSA upon request, including:
- Full ingredient documentation using INCI names
- Product formulation and batch traceability
- Safety and toxicological data (if requested)
4. Advance Notice for Non-Compliant Imports
If your product is not fully compliant at the time of import (e.g., missing bilingual labeling or CNF confirmation), you may be allowed to bring it in—but only if you provide advance notice to Health Canada and correct the issue before sale.
What This Means for You
To sell cosmetics in Canada today, foreign brands must:
- Partner with a Canadian importer or agent
- Keep accurate and up-to-date product records
- Prepare for CNF updates and audits
- Follow evolving labeling and safety disclosure rules
Partner with Progress Therapeutics
Whether you’re launching a new product line or updating an existing CNF, Progress Therapeutics is your full-service import partner. We provide:
- CNF submission and amendment
- Representation as your Canadian Agent
- Health Canada compliance support
- Regulatory tracking and audit preparation
- Customs coordination and documentation handling
Stay compliant. Stay competitive. Trust Progress Therapeutics to help you meet all the current—and emerging—requirements for importing cosmetic products into Canada. Contact us to discuss your importing needs today.