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Canada Proposes to Amend Cosmetic Ingredient Hotlist

Background

The Cosmetic Ingredient Hotlist (Hotlist) is an administrative tool that Health Canada uses to communicate to manufacturers and others that certain ingredients may be prohibited or restricted for use in cosmetics. It consists of two distinct tables, one for ingredients identified as prohibited ingredients and another for those identified as restricted ingredients.

 

1) Prohibited ingredients, including synonyms, salts and related compounds, should not be present in cosmetic products sold in Canada.

 

2) Restricted ingredients are permitted only if the conditions of use and/or cautionary statement(s) are met as outlined in the Hotlist. If the ingredient has a concentration restriction, notifiers to provide the exact concentration used in the product at the time of notification will help expedite Health Canada’s processing of the Cosmetic Notification Form.

 

The Hotlist is a science-based document reviewed and updated periodically when new scientific data becomes available. The last update to the Hotlist was in February 2025.

On May 14, 2025, Health Canada issued a notice regarding the review of proposed amendments to the Cosmetic Ingredient Hotlist. 1 The proposed amendments are:

1) Adding 3 ingredients;

2) Revising 4 ingredients.

1. Proposed Additions

No.

Ingredients

Proposed Amendments

Reasons

1

Basic Violet 4

Conditions being considered for addition include restricting the use of Basic Violet 4 in cosmetics to certain product types, with maximum permitted concentrations for those product types.

Further to the Chemicals Management Plan (CMP) assessment under the Canadian Environmental Protection Act, 1999 (CEPA 1999), Basic Violet 4 will be proposed for addition to the list of substances described as restricted due to potential carcinogenicity. At the time of the CMP assessment, Basic Violet 4 was associated with health effects of concern, however at levels of exposure considered in the assessment, the risk to human health was considered low. Since then, based on cosmetic notifications submitted to Health Canada after the CMP assessment period, levels of exposure have increased and may now pose a risk.

2

Basic Blue 7

Conditions being considered for addition include restricting the use of Basic Blue 7 in cosmetics to certain product types, with maximum permitted concentrations for those product types.

Conditions being considered for addition include restricting the use of Basic Blue 7 in cosmetics to certain product types, with maximum permitted concentrations for those product types.

3

Polyaminopropyl Biguanide (CAS 32289-58-0; 27083-27-8; 28757-47-3, also known as PHMB)

1. Prohibition of PHMB in cosmetic spray formulations is being considered, since inhaling PHMB through products that create mists, vapours or aerosols may affect lung function;

 

2. For other topically applied products where exposure by inhalation is not possible, maximum permitted concentrations will be proposed due to risk of skin sensitization.

Further to the CMP assessment under the CEPA 1999, Polyaminopropyl Biguanide will be proposed for addition to the list of substances described as restricted.

2. Proposed Revisions

No.

Ingredients

Current Requirements

Proposed Amendments

Reasons

1

Symphytum spp., with the exception of Symphytum officinale

Prohibited

A revision to the entry is being considered to remove the exception of Symphytum officinale.

It was previously excluded from the entry as past studies suggested it did not contain echimidine, a hepatotoxic alkaloid. However, echimidine has since been detected in some S. officinale derivatives and S. officinale is also known to contain other carcinogenic pyrrolizidine alkaloids, such as lasiocarpine.

2

Brucine

Restricted, with a maximum concentration of 0.1%.

1. A revision to the entry to describe it as prohibited is being considered.

The substance raises safety concerns due to its high acute toxicity, known neurotoxic properties and significant potential for dermal absorption. Additionally, currently available information is considered insufficient to address potential long-term adverse health effects from repeated exposure to cosmetic products containing brucine.

2. An expansion of the entry to Brucine and its salts is also being considered

The toxicity of salts, such as brucine sulfate, is anticipated to be similar to that of brucine based on their ability to dissociate and release brucine ions.

3

Imperatorin

Prohibited

It is being considered for removal from the prohibited list. Imperatorin would instead be considered subject to the entry for Furocoumarins.

Imperatorin is expected to have phototoxic and photomutagenic effects similar to other furocoumarins.

4

Furocoumarins, except for naturally occurring in plant extracts

Restricted, with a maximum concentration of 1 ppm in sun tanning products.

A revision to the entry is being considered to indicate Furocoumarins are not permitted to be added to products as ingredients and would only be permitted at trace amounts when naturally occurring in plant extracts.

Furocoumarins have been associated with phototoxicity, photomutagenicity and photocarcinogenicity reactions when combined with exposure to UVA radiation. The current maximum permitted concentration would be proposed to apply to all leave-on products, not just sun-tanning products, because sun exposure may occur following the use of any leave-on cosmetic product.

3. Other Miscellaneous Revisions

In addition to the above changes, existing ingredient entries may be revised to include new synonyms, CAS numbers as well as other minor corrections, such as fixing typos.

4. Ingredients under CMP Assessment

The following ingredients are currently being assessed under the Chemicals Management Plan (CMP). Preliminary assessments suggest potential risks associated with their use in cosmetics. If these findings are confirmed in the final assessments, they may lead to future updates to the Cosmetic Ingredient Hotlist.

While these ingredients may not appear in the upcoming consultation, sellers are advised to stay informed about the CMP process and assess which of their products could be affected by potential regulatory changes.

  • Acyclic, Monocyclic, and Bicyclic Monoterpenes Group

  • Alcohols Group

  • Boric acid, its salts and its precursors

  • Fourteen Terpene and Terpenoid Substances Group

  • Gas Oils and Kerosenes with Uses in Products Available to Consumers Group

  • Low Boiling Point Naphthas Group

  • Monocyclic and Bicyclic Sesquiterpenes Group

  • Parabens Group

  • Phenylpropanoids and Aldehydes Group

  • Salicylates Group

  • Tricyclic Sesquiterpenes and Triterpenoids Group

Further Reading

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