There is more to getting into the Canadian cosmetics business than a Cosmetic Notification Form (CNF). B2B cosmetics manufacturers and regulatory teams need to ensure product classification, ensure ingredients are not on Health Canada’s Cosmetic Ingredient Hotlist, and ensure the label is compliant with the regulations before commercial distribution. Incorrectly classified products or claims, or claims that fail to meet standards, may lead to delays in importation, enforcement measures or product removal from the market.
This guideline outlines the regulatory conditions and cosmetic notification process, as well as the rules for cosmetics labeling, timelines and steps for compliance in Canada.
Regulatory Authority for Cosmetic Regulations in Canada
Cosmetics are regulated by Health Canada under the Food and Drugs Act (FDA) and the Cosmetic Regulations.
It is mainly focused on ensuring the safety, quality, and correct labelling of cosmetic products in the Canadian marketplace. Other pieces of legislation, such as the Consumer Packaging and Labelling Act (CPLA), the Canadian Environmental Protection Act, 1999 (CEPA) and the Cannabis Act (if applicable) must also be fulfilled.
Cosmetic Product Classification in Canada
According to the Food and Drugs Act, a cosmetic would be defined as “Any substance or mixture of substances, manufactured, sold or represented for use in cleansing, improving or altering the complexion, skin, hair, or teeth, including deodorants and perfumes.”
This includes:
- Cosmetics for professional cosmetic services
- Bulk supplies (hand soap) in school restrooms
- “handmade” cosmetics made by people who sell cosmetics from home or at craft sales
Compliance Requirements for Cosmetics in Canada
In Canada, cosmetics sold must be compliant with the Food and Drugs Act, Cosmetic Regulations, and pertinent cosmetic labelling requirements. The following are some important requirements:
Cosmetic Notification Requirement
Prior to selling cosmetic products in Canada, the manufacturer and/or importer must provide Health Canada with a Health Canada Cosmetic Notification Form (CNF).
This form contains in-depth details about the product, the ingredients, the area of application, and the manufacturer’s details. The cosmetic manufacturers are also required to submit a list of ingredients and concentrations in the cosmetic to the CNF. Health Canada assesses these ingredients against the Cosmetic Ingredient Hotlist to determine that they meet the requirements of the regulations.
Ingredient Compliance and Cosmetic Ingredient Hotlist
Cosmetic ingredients in Canada must not be on the prohibited list of the Cosmetic Ingredient Hotlist developed by Health Canada. Ingredients on the restricted list may be used only under specific conditions, such as at or below a certain concentration, in specific product types, or accompanied by a required warning statement.
Good Manufacturing Practices (GMP)
In Canada, cosmetic products must be produced, packaged, stored, and handled in sanitary conditions. Companies will be expected to keep quality control procedures in place to prevent contamination and to ensure the consistency of the product.
Safety & Post-Market Compliance
Health Canada post-commercialization monitors cosmetics and may scrutinize a safety issue or investigate claims that do not comply. If a manufacturer or importer knows that information about the product has changed since the notification, they are required to update the notification.
Cosmetic registration process in Canada(Step-by-step)
The Cosmetic Notification Form (CNF) has been developed by the government in order to implement a structured process for manufacturers and importers to comply with regulations for cosmetics set by Health Canada before the cosmetic is commercially distributed in Canada.
Step 1: Validate Product Classification
Prior to submitting a Cosmetic Notification Form (CNF) to identify if the product is a regulated cosmetic, drug, or natural health product in Canada, companies should be aware of the claims and intended use and formulation of their product.
Step 2: Review Ingredients Against the Cosmetic Ingredient Hotlist
All ingredients should be evaluated for prohibited, restricted, or concentration limits and/or warning statements prior to completing the formulation or artwork using the Health Canada Cosmetic Ingredient Hotlist.
Step 3: Make Compliant Product Labels
The Food and Drugs Act and the Consumer Packaging and Labelling Act require cosmetic labels to have bilingual labeling. Labels have to include the product name, net contents, dealer information, ingredient statements (INCI nomenclature), and warnings (in English and French).
Step 4: Review and Compile Necessary Documents and Product Information
The formulation, ingredient concentrations, manufacturer or importer information, label artwork, and supporting safety information for the CNF submission and compliance verification should be developed by the manufacturer or importer.
Step 5: Submit the Cosmetic Notification Form (CNF)
There is a Cosmetic Notification Form (CNF) that any manufacturer or importer must submit to Health Canada within 10 days of its first sale in Canada.
There are several types of notifications:
- New notifications
- Amendments
- Discontinued sale notifications
Amendment and discontinued sale submissions must contain the cosmetic number assigned.
Step 6: Ensure Post-Market Compliance
Once commercialized, companies will have to keep updated notifications and continuous compliance with the ingredient, labelling, and safety rules. Non-compliant claims, safety issues, or consumer complaints can be raised after market entry, with the possibility of Health Canada investigation.
Documents Required for Cosmetic Compliance in Canada
The following documents and information should be kept by the manufacturer/importer in preparation for cosmetic notification and regulatory compliance in Canada:
- Cosmetic Notification Form (CNF)
- Fill in ingredients in full using INCI names
- Use the proper product and concentration in the product
- Bilingual product labels/artwork
- Information about the manufacturer and importer
- Information about the functions and usage of a product
- Warning statements required (if applicable)
- Provide safety or toxicological information
- Records for compliance with the Cosmetic Ingredient Hotlist for ingredients
Health Canada may ask for more product information, labels, or safety data during compliance review and/or post-market investigation.
Labeling Requirements for Cosmetics in Canada
Cosmetic labels in Canada are subject to the Food and Drugs Act, Cosmetic Regulations, and Consumer Packaging and Labelling Act.
The following are required for the label:
- The characteristics of the product or its purpose
- The number of items that will be delivered
- Information about the dealer or manufacturer
- The ingredients are presented in the list using INCI names
- Statements required by the regulations
- Instructions for safe use (if required)
- All mandatory information in English and French (except the names of ingredients in the INCI list)
- Clear, visible, and easy-to-understand label information when consumed
Restricted ingredients found on Health Canada’s Cosmetic Ingredient Hotlist will also need to meet conditions of use and warning statements.
Timeline for Cosmetic Market Entry in Canada
The process to get into the Canadian market for cosmetics varies depending on formulation review, labelling readiness, and submission of the Cosmetic Notification Form (CNF).
| Activity | Estimated Timeline |
| The classification and evaluation of ingredients in products | 1–2 weeks |
| Cosmetic Ingredient Hotlist review | 3–7 business days |
| Adaptation of labels and artwork (bilingual) | 1–3 weeks |
| Completed and submitted CNF and supporting documents | 3–7 business days |
| Cosmetic Notification Form (CNF) submission | Within 10 days after the first sale in Canada |
| Requests for follow-up and/or clarification by Health Canada | 2–6 weeks |
Incomplete disclosure of ingredients, non-compliant claims, or inaccurate labeling, however, can slow down the commercialization process or result in compliance action.
Conclusion
In order to sell cosmetics in Canada, manufacturers and importers need to follow the requirements of Health Canada’s Cosmetic Regulations, the Cosmetic Notification Form (CNF) and ingredient restrictions, as well as the requirement to label the product in both English and French. This involves the correct classification of the product, checking ingredients on the Cosmetic Ingredient Hotlist, creating labels, and ensuring post-market compliance once the product has gone on the market.
Avoiding labeling problems, reformulation delays, and import-related compliance actions when entering the market is possible by early initiation of the compliance process.
Artixio provides cosmetic compliance, CNF submission, ingredient review, and bilingual labelling services for cosmetic companies to help them get products to the Canadian market. Contact Artixio for regulatory assistance: info@artixio.com.
