To address industry stakeholders' concerns about meeting the timeline, on February 21, 2025, Health Canada’s Consumer and Hazardous Products Safety Directorate sent a notice to stakeholders clarifying the phased approach to compliance.

Phase 1: From April 12, 2026 to April 11, 2027: Health Canada will focus on compliance promotion, which include:

• Providing education, guidance, and information to industry and stakeholders;

• Collaborating and consulting with stakeholders;

• Supporting the development of policies, guidelines, standards and regulations.

However, if Health Canada receives health or safety-related incidents or complaints once the initial 24-allergen labeling requirement takes effect (April 12, 2026), it will respond using its usual risk-based process.

Phase 2: From April 12, 2027 Onward: Compliance & Enforcement

• Enforcement actions will follow a risk-based approach in line with standard departmental and program guidance.

All other transition periods associated with the amendments to the Cosmetic Regulations outlined in Canada Gazette, Part II, Volume 158, Number 9 remain unchanged.

Webinar Recommendation

ChemLinked invited an experienced regulatory affairs consultant, Marina Bishop from CE.way, to explain requirements on exporting OTC cosmetic products to the USA and Canada. This session will cover essential regulatory requirements, market insights, and other vital considerations. By the end of this webinar, regulatory professionals and organisations will have a better understanding of the regulatory landscape surrounding OTC products in both USA and Canada and will gain valuable insights into how to export OTC cosmetic products successfully.

Further Reading

• Canada Requires Cosmetics to Be Labeled with Fragrance Allergens

• Canada Issues Significant New Activity Notice for Trisiloxane in Cosmetics

• Taiwan Introduces New Labeling Requirements for 24 Fragrances and Flavorings