Canada lets you sell first, then notify within 10 days
Most buyers assume a cosmetic notification has to clear before the first shipment moves. Canada runs the other way round. The form is due within 10 days after the first sale, every ingredient carries a concentration range code, and from 12 April 2026 fragrance allergens appear on the label by name.
Canada has no pre-market approval. The Cosmetic Notification Form (CNF) is due within 10 days after a cosmetic is first sold in Canada, and every ingredient is filed under its INCI name with an exact concentration or one of 13 range codes. A notification number is not an approval. Fragrance allergen disclosure starts with 24 allergens on 12 April 2026 and widens to 81 for new products on 1 August 2026.
No approval queue, but a ten-day clock
The step Korean suppliers most often get wrong about Canada is not a document — it is the order of events. The EU and the UK want the notification closed before a product is placed on the market. Canada asks for the Cosmetic Notification Form (CNF) within 10 days after the first sale, under section 30 of the Cosmetic Regulations, and the filer is the Canadian manufacturer or importer.
There is no pre-market review and no filing fee. Health Canada issues an eight-digit cosmetic number once the submission is processed, and its guide is blunt about what that number is worth: receiving it "does not constitute approval of the product." Buyers who read the number as a customs clearance tend to discover otherwise at the border.
The same ten days then recur three more times. A formula or contact change triggers a revised notification within 10 days, a discontinued product a cessation notice within 10 days, and a Health Canada information request an answer within 10 days. Miss any of them and sale of the product is prohibited, so Canada is not a market where one filing closes the file.
| Market | Notification timing | Who files |
|---|---|---|
| Canada | within 10 days after first sale | Canadian manufacturer or importer |
| EU | before placing on market | EU Responsible Person |
| UK | before placing on market | UK Responsible Person |
| United States | within 120 days of first sale, renewed yearly | Responsible Person on the label |
One English word, four different moments. The United States is also post-market, but its 120-day window is twelve times longer than Canada's. If a first Canadian shipment is already scheduled, the CNF inputs need to exist by the time label artwork goes to print.
You file a concentration table, not an ingredient list
The field that stalls most Korean files is concentration. INCI names alone are not enough: every ingredient needs either an exact percentage or one of thirteen range codes.
| Code | Concentration |
|---|---|
| 1 | above 80% up to 100% |
| 7 | above 10% up to 20% |
| 9 | above 1% up to 3% |
| 11 | above 0.1% up to 0.3% |
| 13 | above 0% up to 0.001% |
Totals have to add up to 100%, with batch-variable ingredients flagged under "may contain". Ranges do spare you from handing over an exact percentage, yet knowing whether an active sits in code 9 or code 10 is close to formula-level information. If an ODM agreement says nothing about supplying range codes, the notification stops there.
The form also classifies each ingredient as known, restricted, prohibited or not found. A single prohibited entry on the Cosmetic Ingredient Hotlist means the product cannot be sold as a cosmetic in Canada at all — worth checking before you look at demand on today's ingredient signals.
The allergen list is the EU's, adopted wholesale
SOR/2024-63, published in the Canada Gazette in April 2024, brought individual fragrance allergen disclosure to Canada. The list is the EU's Annex III, taken over as it stands, and it arrives in phases.
From 12 April 2026, 24 allergens must appear on the label and in the notification outside the term "parfum", above 0.01% in rinse-off products and 0.001% in leave-on products. From 1 August 2026 the full set of 81 applies to new cosmetics, and products already on sale have until 1 August 2028.
One thing shifted this year. A notice dated 6 March 2026 confirmed that reporting allergen concentrations in the CNF is generally optional — an interpretation of the existing rules rather than an amendment. Allergens restricted on the Hotlist may still need concentration data, so a file that has been waiting on numbers from a fragrance house is worth revisiting.
Both official languages on the same panel
Canadian labels are bilingual by default. Product name, net quantity, consumer contact information, dealer identity and address, warnings and directions for safe use all have to appear in English and French. The ingredient list is the single exemption, and it runs in INCI names.
That is why a Korean domestic carton with an English sticker does not survive Canadian retail. French copy needs back-panel area, and on small primary containers it usually forces a peel-label or an outer carton. Those are cost lines, not artwork lines, so price them with the quotation — the product planner is the quickest way to compare pack options before asking for samples.
Korea is already the third-largest supplier
The paperwork is heavier than Canada's market size suggests. In KOTRA's compilation of Canadian skin-care imports (HS 3304.99), Korean product ranked third in 2023 at C$121.7 million, up 49.5% from C$81.4 million in 2022, for a 6.5% share.
MoCRA and Canada open different doors with different keys. MoCRA splits its obligations between the factory that registers and the Responsible Person named on the label; Canada bundles concentration data and bilingual artwork into one notification. A completed US file does not transfer across.
«Takeaways»
- No pre-market approval in Canada, but the CNF is due 10 days after first sale — and amendments, cessations and information requests run on the same clock.
- Every ingredient is filed with an INCI name plus an exact concentration or a code from 1 to 13, totaling 100%.
- Fragrance allergens: 24 from 12 April 2026, 81 for new products from 1 August 2026, existing products by 1 August 2028.
- Labels carry English and French, with only the ingredient list exempt. Budget the extra panel area into unit cost.
*Sources: Health Canada, Notification of Cosmetics: Guide for Cosmetic Notifications (canada.ca, accessed 1 November 2026) · Health Canada, Cosmetic advertising, labeling and ingredients (canada.ca) · SOR/2024-63, Canada Gazette Part II (April 2024) · Health Canada notice on fragrance allergen concentration reporting (6 March 2026) · U.S. FDA guidance on MoCRA cosmetic product listing · KOTRA, Canadian skin-care market report (HS 3304.99, 2023)*
What this means for your Korean private label product
Rules like this (Canada) land on the brand owner, but most of the evidence comes from the manufacturer. As a Korean private label (OEM/ODM) partner we prepare the formula data, test reports and label review your filing needs.
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Questions people ask
No. It is due within 10 days after the first sale in Canada, under section 30 of the Cosmetic Regulations. That is the opposite of the EU and the UK, where notification must be complete before the product goes on the market.
Neither. Health Canada issues an eight-digit cosmetic number once the file is processed, and its own guide states that receiving a notification number does not constitute approval of the product. It will not clear customs for you.
Each ingredient needs its INCI name plus an exact concentration or one of 13 range codes — code 1 is above 80% up to 100%, code 9 is above 1% up to 3%. The declared total has to reach 100% unless variable ingredients are flagged as "may contain".
Usually not any more. A 6 March 2026 notice confirmed that concentration reporting is generally optional, though allergens restricted on the Cosmetic Ingredient Hotlist may still need concentration data depending on the restriction.
No. Canada requires English and French for the product name, net quantity, contact information, dealer identity, warnings and directions. Only the ingredient list is exempt, and it must use INCI names.