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[Updated] Canada Updates Cosmetic Notification Form

Editor's note: This article was originally published on January 21, 2025, and was updated on March 6, 2025, as per the latest developments. The updated contents are marked in red below.

Background

Manufacturers or importers are obligated to submit a Cosmetic Notification Form (CNF) to Health Canada within 10 days from the first sale of a cosmetic in Canada. In the case of imported products, it is advisable to notify Health Canada before the importation takes place. Failure to notify may result in the denied entry into Canada or removed from sale.

According to a notice sent from Health Canada, the CNF was updated in March 2025.

Health Canada highlighted the updates in Section 4, introducing a validation feature that requires a Canadian address for the manufacturer or importer. As a result, all new cosmetic notifications and amendments must include a Canadian address in Section 4. Therefore, to export cosmetics to Canada, a company must either establish a Canadian entity or appoint a Canadian agent. According to Ecomundo, the Canadian agent has no direct responsibility for product compliance, adverse event management, or ongoing monitoring. Instead, it acts as a local point of contact between the foreign brand and Health Canada, facilitating communication in case of inquiries or audits. While the agent’s name and address appear in CNF declarations, they are not required on product labels. 1

The key updates to the CNF and considerations for companies are outlined in the table below. Enterprises do not need to resubmit notifications for previously notified products if the information remains accurate. However, if any details change, the manufacturer or importer must submit a revised notification within 10 days of the change.

Section of CNF

Updates

Reminder

Section 2: Product

1) A new optional field will be introduced for directions of use, allowing notifiers to input usage instructions as they appear on the product label;

2) Additionally, a new optional field for warning and cautionary statements will be added, enabling notifiers to include these statements as displayed on the label.

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Section 3: Notifier

A new field will allow the notifier to specify their preferred language of correspondence.

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Section 4: Manufacturing, importing, label and other contact

1) The section will be renamed to “Manufacturing, Importing, Label, and Other Contact” to better reflect its purpose;

2) A new contact type, “Formulator or Third-Party Manufacturer,” will be added. This contact type refers to the person who formulated the cosmetic or the third party who manufactured the cosmetic;

3) Importers must include information about the person or organization that formulated, manufactured, or processed the product on their behalf. Use the “Formulator or Third-Party Manufacturer” contact type for this purpose;

4) A Canadian address will be mandatory for manufacturers or importers. The system will validate and require a Canadian address in this section.

In addition to the “manufacturer” or “importer” information required under the Cosmetic Regulations, details about the “label contact” must always be provided.

Section 5: Product ingredients

1) The “Ingredient Name” section will clarify that either the “INCI Name” or “Chemical Name” must be provided;

2) The “INCI Name” search function will display up to ten entries in the drop-down menu (implemented in November 2024);

3) A new subsection titled “Concentration” will precede the “Exact Concentration" field;

4) Notifiers must either provide the “exact concentration” or select an appropriate “concentration range;”

5) When selecting a concentration range, the upper and lower concentration fields will reflect the updated concentration ranges. Once selected, the upper and lower concentration fields cannot be edited;

6) A “Reset Concentrations” button (implemented in November 2024) will allow notifiers to clear concentration data if entered incorrectly.

1) If an ingredient lacks an INCI name or shows as “Not Found” when using the search function, enter its name in the “Other Chemical Name” field;

2) Use the “Search Ingredient” button to validate the ingredient. Any applicable conditions will appear in the “Condition of Use” field;

3) Notifications containing “Not Found” ingredients can still be submitted but may trigger further review by Health Canada. Double-check spelling, spaces, and punctuation before submission;

4) Additional documents, such as Material Safety Data Sheets (MSDS) or Certificates of Analysis, can be uploaded in Section 6 to help identify “Not Found” ingredients.

Section 6: Documents and pictures

1) According to paragraph 30(1)(b) of the Cosmetic Regulations, copies of labels and inserts containing the required information (per paragraph 22–24) must be submitted with the notification;

2) Choose “Label - Text” for text-only labels or “Label - Marketplace” for labels with graphics or printer proofs.

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Section 9: How to view/edit the previous CNF

1) For amendments, once the previously saved hcxs file is uploaded, information about the product type (e.g., leave-on or rinse-off) will be required;

2) When submitting amendments, notifiers must provide either the exact concentration or make a selection from the updated concentration ranges before submission;

3) For discontinuation notifications (starting   from October 9, 2024), newly required fields will not be mandatory for the “discontinue sale” notification type.

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To assist stakeholders, the Guide for Cosmetic Notifications and its Appendix 2 have been revised accordingly.

Further Reading

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