Selling a fragrance in Canada and Australia

Two countries, two opposite approaches

Both are reachable markets for a small house, both speak English, and neither follows the European Union. They are worth learning together because they are almost mirror images of each other, and knowing which is which saves a great deal of reading in the wrong place.

Canada: notify within ten days of the first sale

Canada requires a Cosmetic Notification Form to be submitted to Health Canada, and the timing is the part people get wrong: it is due no later than ten days after the product is first sold in Canada, not before. You may sell first. You may not sell and then forget.

The form asks for the product identity, the company responsible for it, where it is manufactured, its product type and its ingredients with their concentrations, which are given as ranges rather than as exact figures. Like the EU portal, it is a notification and not an approval: nobody writes back to say yes, and a submitted form is not a license.

It has to be kept current. A change of formula, of company details or of product name means an amended notification rather than a note in a file.

Canada: the Hotlist is not the EU annexes

Health Canada publishes the Cosmetic Ingredient Hotlist, which names substances prohibited or restricted in cosmetics sold in Canada. It does the job the EU's Annex II and Annex III do, and it is not a copy of them.

That is the trap. A material cleared for an EU product is not thereby cleared for Canada, and a material Canada permits may be restricted in the EU. The Hotlist is administrative rather than a regulation in its own right, which means it can be updated without a legislative process, so it is checked at the version current when you file rather than remembered from last year.

Canada: the allergen rules just changed, and they follow the EU

This is the newest thing on this page and the one most likely to catch a seller out, because it landed while most guidance was still describing the old position.

Canada now requires fragrance allergens to be named individually in the ingredient list, at the same thresholds the European Union uses: above 0.001 percent in a leave-on product and above 0.01 percent in a rinse-off one, both as percentages of the finished product. They also have to be disclosed individually in the notification form rather than grouped under fragrance.

The practical consequence is a good one for anybody already selling into the EU: the allergen work is the same work. The figures you calculated for an EU label answer the Canadian question too, and the two lists are meant to stay in step. It is the opposite of the Great Britain position, where the lists have come apart.

Canada: bilingual labels

Canadian labels must give the mandatory information in both English and French. The ingredient list itself is in INCI, which is the same in both languages and is not translated, but the words around it are: the product identity, the net quantity, warnings and directions.

This is the requirement that most often forces a separate Canadian carton rather than a shared North American one, and it is worth knowing before the artwork is drawn rather than after.

Australia: you are introducing industrial chemicals

Australia treats the ingredients in a cosmetic as industrial chemicals, and regulates the act of bringing them into the country. Anybody who imports or manufactures them must register with the national scheme, and there is no minimum volume: one bottle imported for sale counts.

Registration is annual, and there is an annual declaration of what was introduced during the year. The framing takes some getting used to, because a perfumer does not think of themselves as a chemical importer, but that is the door you come in through.

Every ingredient must be one Australia already knows about, meaning it appears on the national inventory. A material that is not on it is a new chemical and needs its own assessment before it can be introduced at all. For a house working from established aroma materials this is usually satisfied already, and it is exactly the kind of thing to check before committing to an unusual captive or a novel isolate.

Australia: what the label must carry

Separately from the chemicals scheme, Australia sets out what a cosmetic label has to say. In outline it is familiar: the full ingredient list in INCI names, in descending order of proportion with anything under one percent in any order, the net quantity, a batch identifier, and the name and address of the manufacturer or importer within Australia.

The two obligations are genuinely separate and it is worth holding them apart. One is about whether the chemicals may enter the country. The other is about what the customer is told. Satisfying one says nothing about the other.

What transfers from work you have already done

None of the filings transfer. All of the underlying data does, and that is most of the effort.

• The composition of every material, and the percentage of each one in the finished product. Needed by all four regimes on this site.
• The allergen figures. Now literally the same question in the EU and Canada, and useful groundwork everywhere else.
• The IFRA assessment, which is industry-wide and not tied to any country.
• The INCI ingredient list, which is the same nomenclature in every market that uses it.

What does not transfer is the paperwork: a Canadian notification, an Australian registration, an EU or GB portal submission and a US listing are four separate acts against four separate bodies, each wanting the same facts in its own arrangement.

How Orris Bench handles this

The markets a product is sold into are a fact you state once, per product, and it can be more than one. The compliance work underneath, the composition, the allergen figures and the IFRA position, is done once against the formula and read by each market rather than repeated per country.

Because the allergen threshold and the finished-product basis are the same question in the EU and in Canada, an allergen declaration prepared for one is prepared for the other, from the same batch record and at the same strength.

Sources

The Canadian requirements are from Health Canada's guidance on cosmetic notification, its Cosmetic Ingredient Hotlist and its industry guide to cosmetic labeling, together with the published guidance on the fragrance allergen disclosure dates of 12 April 2026, 1 August 2026 and 1 August 2028. The Australian requirements are from the national industrial chemicals scheme's own guidance for cosmetics and from the applicable consumer information standard for cosmetic labeling. Both sets move, and both governments publish their current text free. This page is written for people who make fragrances and it is not legal advice; check the current guidance before relying on any statement.