Proposed regulations for fragrance allergen ingredient labeling in Canada

Health Canada is proposing new regulations that would require fragrance allergen ingredient labeling on all cosmetic and personal care products sold in Canada. The proposal is aimed at increasing transparency and protecting consumers from potential allergic reactions to fragrance ingredients.
 
Fragrance ingredients are commonly found in a wide range of products, including perfumes, colognes, shampoos, body washes, and lotions. However, many fragrance ingredients have been linked to allergic reactions, skin irritations, and respiratory problems in sensitive individuals.
 

Proposed Regulatory Changes for Disclosure of Fragrance Ingredients in Cosmetics

 
The Government of Canada has introduced Senate Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act, in response to growing demand from the public for readily accessible health protection information on chemicals in consumer products, including cosmetics. The government is committed to enhancing the transparency of chemical ingredients and making their presence more visible through labeling. The Cosmetic Regulations under the Food and Drugs Act already require the disclosure of all ingredients on the label of a cosmetic. However, fragrance ingredients are typically complex mixtures of many different ingredients at very low or trace amounts, and the entire fragrance composition of a cosmetic is not required to be disclosed on the product label. Instead, fragrance ingredients must be indicated either by individually identifying them or using the term “parfum.”
 
Disclosure of fragrance allergens is important for public health and safety, as fragrance ingredients are the most common cause of contact allergies to cosmetics, and allergic contact dermatitis (ACD) is a lifelong condition. The current flexibility for ingredient disclosure for cosmetics sold in small packages is also lacking a modern and sustainable option, and the regulatory oversight of cosmetics needs updating to improve the definition of “manufacturer” and “importer” and clarify their responsibilities. The proposed changes are in line with international naming conventions for cosmetics and would make Canada’s regulations more closely aligned with those of the European Union and the United States.
 

Current Regulations on Fragrance Ingredients in Canadian Personal Care Products

 
Currently, Canadian regulations require that cosmetic and personal care products list all ingredients on the label, but fragrance ingredients are often lumped together under the term “fragrance” or “parfum.” This makes it difficult for consumers with fragrance allergies to identify which specific ingredients are causing their reactions.
 

Proposed Regulations on Fragrance Allergen Ingredient Labeling

 
Under the proposed regulations, fragrance allergen ingredients would be listed separately on product labels, allowing consumers to make more informed choices and avoid potential allergic reactions. The proposed list includes 26 fragrance allergen ingredients identified by the European Union and other international organizations as being of concern for allergic individuals.

Some of the fragrance allergen ingredients proposed for mandatory labeling include geraniol, eugenol, linalool, and limonene. These ingredients are commonly used in fragrances and have been identified as potential allergens by health organizations.
 

Requirements for Fragrance Allergen Ingredient Labeling

 
The proposed labeling requirements have received support from consumer advocacy groups and health organizations, who argue that increased transparency will benefit consumers and promote safer use of cosmetic and personal care products.

However, some industry groups have expressed concerns about the potential impact of the new regulations on businesses. The Canadian Cosmetic, Toiletry, and Fragrance Association (CCTFA) has argued that mandatory labeling requirements would be costly and difficult to implement and could lead to job losses and reduced innovation in the industry.

Despite these concerns, Health Canada has emphasized the importance of protecting consumers from potential harm and ensuring that they have access to accurate information about the products they use.

Health Canada is encouraging consumers, industry stakeholders, and other interested parties to provide feedback on the proposed labeling requirements.

If the regulations are approved, Canada will join other countries, including the European Union, that require fragrance allergen ingredient labeling on cosmetic and personal care products.

In conclusion, the proposed requirement for fragrance allergen ingredient labeling in Canada is a positive step towards increasing transparency and protecting consumers from potential allergic reactions. While there may be concerns about the impact on businesses, the safety of consumers should always be the top priority. With public input and careful consideration of all perspectives, the regulations can be implemented in a way that benefits both consumers and industry stakeholders.

The proposed regulations would require manufacturers to clearly list fragrance allergens on the labels of cosmetic and personal care products sold in Canada. This is a significant step towards improving the safety of cosmetic and personal care products, as it would help consumers with allergies avoid products that could potentially cause adverse reactions.

Under the proposed regulations, manufacturers would be required to list fragrance allergens if they are present in the product at a concentration equal to or greater than 0.01% (100 ppm). The fragrance allergens that would need to be listed are those identified on the European Union’s list of 26 fragrance allergens. These include commonly used ingredients like citronellol, eugenol, and limonene.

In addition to listing the fragrance allergens, the proposed regulations would also require manufacturers to include a statement on the label advising consumers to perform a patch test before using the product. This would involve applying a small amount of the product to a small area of skin and waiting 24 hours to see if any adverse reactions occur.
 

Final Thoughts on Proposed Regulations and the Importance of Consumer Safety

 
If the proposed regulations are implemented, Canada would join other countries like the European Union and the United States in requiring fragrance allergen labeling on cosmetic and personal care products. This would provide consistency in labeling requirements and improve consumer safety by making it easier for people with allergies to identify and avoid potential allergens in these products.

It is important to note that the proposed regulations are not yet finalized and may be subject to change based on feedback from stakeholders and the public. However, if the regulations are implemented, they would represent an important step towards improving the safety of cosmetic and personal care products sold in Canada.

If you have doubts about the Canadian Cosmetic Regulations, Cosmereg can assist you in each step. For more information just contact us.