Canada Is the First North American Regulator to Mandate Per-Allergen Fragrance Disclosure — Phase 1 Is Already Live

Canada became the first North American regulator to mandate individual fragrance allergen disclosure on labels, with Phase 1 effective April 12, 2026 under SOR/2024-63 — requiring disclosure of 24 core allergens for all new and existing products. Phase 2 (August 1, 2026) expands this to 81 allergens for new products entering the market, aligning with EU Regulation (EU) 2023/1545. The EU's own July 31, 2026 deadline for the same expanded list is now less than 65 days away. In the US, the FDA's proposed rule under MoCRA for fragrance allergen labeling — originally due June 2024, then deferred repeatedly — has a revised target of May 2026 for the NPRM only; a final rule is unlikely before 2027.

The fragrance industry's decades-long ability to shield formulas under the single word "parfum" is ending sequentially across the three largest cosmetics markets — Canada now live, EU weeks away, US following a year or two behind. For clean and natural brands that market fragrance as a point of differentiation (essential oil blends, natural botanical extracts), this is operationally significant: many natural fragrance ingredients — citral, linalool, limonene, eugenol — appear directly on the allergen disclosure lists. A brand positioning itself as "fragrance-free" or "naturally scented" now faces the same labeling scrutiny as a synthetically fragranced product.

Brands that have not initiated their fragrance supplier documentation audits for the Canadian and EU deadlines are already in a compliance gap. The Canadian rule is also the first to require disclosure on existing on-shelf inventory in Phase 1, not just new products — which means retailers, not just brands, carry exposure.