Cosmetics Compliance

services for Canada

Appointing a single team with in-house regulatory assessment, product safety and notification services, simplifies the route to the Canadian market. Your products, formulations, ingredients are assessed once and your supporting data and documentation are stored and managed in one single place. This eliminates duplicated work and provides traceability and continuity when details, suppliers or regulatory requirements change.

For each product, we prepare an up-to-date label content brief to support artwork development. It brings together the required ingredient declaration, applicable fragrance allergens, mandatory warnings and use instructions, and other Canadian labelling elements in a practical format that can be shared directly with your artwork and packaging teams.

Instead of sending generic regulatory alerts, we notify you only when action is relevant to your portfolio. TRC keeps track of amendments that impact your products and formulations. We tell you exactly which products are impacted, how they are affected and what action is required, so you can manage remaining stock and adapt your products in time to meet new requirements.

Managing Canada product compliance continues after launch as changes are ongoing. A new supplier, a formulation change, a revised label or an updated ingredient restriction may all call for an update or completely new assessment and, where applicable, an amended Cosmetic Notification Form (CNF) with Health Canada.

Our team connects these changes to the affected products, supporting you to decide what needs to be updated and when.

Our proprietary PRIMS Compliance and Safety Software connects products, formulations and raw materials, their data and documentation, regulatory requirements and toxicology data within one structured compliance environment. This allows TRC to assess safety and the impact of regulatory changes on your portfolio, trace their impact down to individual products and ingredients, and manage compliance and safety information as your products and Canadian requirements develop.

Canadian cosmetic requirements cover a wide range of beauty and personal care products such as skincare, haircare, makeup, fragrances, shampoos and deodorants. A product’s ingredients, presentation and claims can affect its classification. For example, products making therapeutic claims may be classified and regulated as drugs or natural health products instead.

We perform product classification or assess an existing classification and claims early on so that the applicable requirements guide the further product compliance project.

Cosmetics sold in Canada must be safe when used as directed or in the customary way. Health Canada’s Cosmetic Ingredient Hotlist identifies ingredients that are prohibited or restricted, including conditions concerning concentration, product type or warnings. An ingredient’s absence from the Hotlist does not, by itself, establish that it is safe.

TRC assesses both the formulation and the supporting information to substantiate safety and to identify gaps where further information is needed. This process includes assessment based on toxicological and exposure information, stability and microbiological data, specifications and manufacturing controls. We deliver a well documented and high-quality safety assessment report.

Cosmetic products sold in Canada must comply with labelling rules defined in the Cosmetic Regulations and the Consumer Packaging and Labelling Act. TRC prepares label content reports and reviews artwork so that regulatory requirements are addressed before printing. Mandatory label elements include:

• Product identity
• Net quantity
• Ingredient list using INCI nomenclature
• Any required warnings or directions for safe use
• Dealer identification
• Consumer contact information
• Bilingual labelling in English and French (although most INCI names do not require translation into French, certain names must also be provided in French)

Manufacturers and importers must submit a complete Cosmetic Notification Form to Health Canada at the latest within 10 days after a cosmetic is first sold. The notification includes information about the product, ingredients and concentrations, and the relevant businesses and label contact. The CNF requires a Canadian address for the manufacturer or importer.

Successful notification does not mean that Health Canada has approved the product or confirmed its compliance. If previously notified information becomes inaccurate because the formula, product name or company details change, an amended notification is generally required within 10 days.

TRC manages CNF submissions and amendments alongside the underlying product records as part of the continuous compliance service.

A specified list of individual fragrance allergens must be disclosed, stated in the cosmetic product notification, and included in the ingredient list when an allergen’s individual concentration exceeds 0.001% in a leave-on cosmetic or 0.01% in a rinse-off cosmetic.

Canada expanded its disclosure requirements to 81 fragrance allergen entries. This new expanded disclosure requirement applies for new cosmetics placed on the market after 1 August, 2026. Cosmetics already on the market must meet the expanded disclosure requirement by 1 August, 2028.

We assess the compositional data and documentation of fragrances and other raw materials containing allergens that are part of the product formulation, and identify the required ingredient disclosures for the label and CNF.