Cosmetic Labelling in Canada vs. the United States: The Core Differences That Impact Packaging

For cosmetic brands expanding across North America, label compliance is a common regulatory hurdle and can be expensive to fix if done incorrectly. 

While Canada and the U.S. share many labelling similarities in ingredient listing and general misbranding rules, there are critical structural differences in language requirements, notifications, and allergen disclosure that directly affect packaging design, artwork timelines, and launch strategies. 

This overview breaks down the key differences that brands should consider before going cross-border. 

Regulatory Oversight: Who Controls What? 

In Canada, cosmetics are regulated by Health Canada, under the Food and Drugs Act and Cosmetic Regulations, along with elements from the Consumer Packaging and Labelling Act. 

In the U.S., cosmetics fall under the authority of the U.S. Food and Drug Administration (FDA) pursuant to the Federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act. 

While neither country pre-approves cosmetic labels before sale, compliance expectations differ in practical application. 

The Core Differences That Impact Packaging 

1. Bilingual Labelling (Canada Only)

Canada requires mandatory information to appear in both English and French, including: 

• Product identity 

• Net quantity 

• Warnings and cautions 

• Directions for safe use 

• Dealer name and address 

Ingredient lists use the INCI naming system and so do not require translation. 

Brands and manufacturers must also consider the French language requirements as mandated by Québec’s Bill 96, including its impact on trademarks and inclusion of descriptive terms.  

The U.S. requires English. If a foreign language is used, English must also appear. 

Impact: Space constraints often lead to a Canada-specific label or extended packaging format (e.g., peel-back labels) to accommodate bilingual labelling. 

2. Cosmetic Notification Requirement (Canada Only)

Canada requires submission of a Cosmetic Notification Form (CNF) within 10 days of first sale. 

The U.S. does not require mandatory pre-market filing for cosmetics, however through the Modernization of Cosmetics Regulation Act (MoCRA) facility registration and product listing requirements exist under these regulations. 

Impact: Canada requires regulatory preparation before or immediately upon market entry and information declared on the CNF must match the information declared on the label. 

3. Fragrance Allergen Disclosure (Emerging Divergence)

Canada has implemented expanded fragrance allergen disclosure requirements aligned more closely with European Union (EU) practices. Currently, a list of 81 allergens must be listed when present above prescribed thresholds (> 0.01% in rinse-off products and > 0.001% in leave-on products). In April 12, 2026, all cosmetic products (new and old) were required to disclose 24 fragrance allergens within the list of ingredients when these thresholds were met. After the expansion to 81 allergens, as of August 1, 2026, all new cosmetics are required to disclose any of the 81 allergens that meet the thresholds. Only products that were notified prior to this date have a transition timeline of August 1, 2028 to update their labels to include allergens on the expanded list. They must already declare allergens from the original 24 allergen list.  

The U.S. does not currently mandate individual fragrance allergen disclosure. The state of California requires reporting of certain fragrance allergens but does require them to be displayed on the physical product packaging or retail label. Under MoCRA, the FDA is required to issue regulations that establish a list of fragrance allergens that must be disclosed on a product’s label, but at this time FDA has delayed the publication of its proposed rule on fragrance allergen labelling. Until the rule has gone through public comments and then a final rule is published, the FDA cannot mandate allergen labelling. 

Impact: U.S. companies that currently do not incorporate fragrance allergens on their label, will need to consider Canada-specific labels or revising their ingredient listing labelling strategy. 

4. Net Quantity Formatting

Canada requires metric units and bilingual presentation (where applicable). Imperial units are permitted but only when presented as supplementary information to the main declaration. 

The U.S. requires U.S. customary units; metric equivalents are commonly included. 

Impact: Dual-declaration formatting must be structured correctly to satisfy both jurisdictions. 

Strategic Considerations for Brands Expanding Across North America 

When preparing cosmetic products for both Canada and the U.S., regulatory compliance should be considered before packaging artwork is finalized. Key considerations include: 

• Review the formula for both markets: Ingredient restrictions, colour additives, and fragrance allergen requirements can differ between Canada and the U.S. 

• Build regulatory requirements into artwork early: Bilingual requirements and jurisdiction-specific information can significantly affect available label space. 

• Coordinate product information: Ensure the product name, identity, ingredients, warnings, directions, and net quantity are consistent with the regulatory information submitted or maintained for each market. 

• Review claims before launch: Marketing language, product descriptions, website content, and packaging should be reviewed together to avoid creating regulatory inconsistencies. 

• Plan for regulatory updates: Requirements can change after artwork has been approved, so maintaining a regulatory review process helps prevent outdated labels from entering production. 

• Conduct a final pre-production label review: A regulatory check before printing can help identify issues while they are still inexpensive to correct. 

The key takeaway: A successful North American launch requires more than simply translating a U.S. label into French. Regulatory requirements should be evaluated for each market and incorporated into the product, packaging, and marketing strategy from the beginning.