Cosmetic and Personal Care Co-Packing in Canada: Notification, Labelling and Choosing a Filler

By COPACK Canada · October 25, 2026

Beauty and personal care brands can often move from a finished formula to a filled bottle faster than food brands can. There’s no pre-market approval for most cosmetics in Canada. That speed hides a few obligations that catch founders out: a notification deadline measured in days, an ingredient list with its own naming system, a label that must work in two languages, and a fragrance allergen rule that changed in 2026. Here is what to settle before your co-packer fills the first unit.

Step 1: Make sure it’s actually a cosmetic

Under the Food and Drugs Act, a cosmetic is a substance used to clean, improve or alter the complexion, skin, hair or teeth, including deodorants and perfumes. Health Canada says a beauty product becomes a drug if it claims to modify body functions or to prevent or treat disease. Its own examples of products that are not cosmetics include acne treatments and anti-dandruff shampoos. Products represented for sun protection are also regulated as drugs or natural health products and carry a DIN or NPN.

Some familiar products stay on the cosmetic side when they’re positioned carefully. Health Canada classifies aluminium-based antiperspirants as cosmetics when they’re represented for reducing normal underarm perspiration, and lotions containing sunscreen ingredients without any sun-protection representation are listed as cosmetics. The lesson: your claims decide your category. Write the label copy before you choose a co-packer, because a drug or NHP needs a licensed facility and a different approval path.

Step 2: Check every ingredient against the Hotlist

Health Canada maintains the Cosmetic Ingredient Hotlist, a list of ingredients that are prohibited or restricted in cosmetics, with conditions such as maximum concentrations or required warnings. A formula that is legal elsewhere can still fail in Canada. Ask your formulator or co-packer to screen the full formula, including fragrance components and preservatives, before you order packaging.

Step 3: Notify Health Canada within 10 days of first sale

Section 30 of the Cosmetic Regulations requires every manufacturer and importer to file a Cosmetic Notification Form (CNF) no later than 10 days after first selling a cosmetic in Canada. Under section 15.3, the product can’t be sold after that 10-day window if the notification hasn’t been provided, and Health Canada warns that missing notifications can lead to products being refused entry or removed from sale. If the formula, name or contact details change, a revised notification is due within 10 days.

Two points matter when a co-packer is involved:

• Agree who files. The regulations put the duty on the manufacturer and importer. Brands that contract out filling should settle in writing who submits the CNF and who keeps it current.
• Notification isn’t approval. Health Canada states plainly that a CNF doesn’t mean it has approved the product, agreed it’s a cosmetic or confirmed that it complies.

The contact information on the label should match the contact information on the CNF.

Step 4: Build a compliant label

Health Canada says cosmetic labels must show, among other things, the product identity (for example “moisturizer”), the net quantity in metric units or count, an ingredient list, and the name and address of the responsible company. Required information must be in both English and French, except INCI names. Quebec may have additional French-language requirements.

Ingredient lists use INCI names

Ingredients are listed by their International Nomenclature of Cosmetic Ingredients (INCI) names. Generally they appear in descending order of concentration, with ingredients at 1% or less listed in any order after the rest. Fragrance and flavour can be shown as “parfum” and “aroma,” with one important exception below.

Fragrance allergens must now be named

Since April 12, 2026, new and existing cosmetics must list 24 named fragrance allergens individually in the ingredient list when they are present above 0.01% in rinse-off products or 0.001% in leave-on products. From August 1, 2026, new cosmetics must disclose an expanded list from Health Canada’s labelling guide at the same thresholds. Existing products have until August 1, 2028 to meet the expanded list. Ask your fragrance supplier for an allergen breakdown at your use level, and plan label artwork around it.

Step 5: Choose the right filling and packaging partner

Health Canada requires cosmetics to be manufactured, prepared, preserved, packed and stored under sanitary conditions. Beyond that, the right partner depends on your product:

• Viscosity and fill method. Thin toners, gels, thick creams and balms need different filling equipment. Bring a sample of the finished product, not just the spec.
• Container format. Pump bottles, squeeze tubes, jars, sachets and refill pouches each have different minimums, lead times and compatibility questions. Pouch formats can cut shipping weight for refills. See our packaging formats guide and packaging sourcing options.
• Compatibility and stability. Ask whether your formula has been tested in the actual container and closure. Oils and actives can interact with some plastics.
• Batch records and lot coding. You want to be able to trace any complaint back to a batch of bulk and a fill date.
• Minimums. Fill minimums and component minimums differ. A low fill MOQ doesn’t help if your printed tubes come in tens of thousands. Our page on co-packing costs and MOQs explains how quotes are built.

A short pre-launch checklist

1. Claims reviewed: nothing that crosses into drug or NHP territory unless you intend it to.
2. Full formula screened against the Cosmetic Ingredient Hotlist.
3. Fragrance allergen data in hand and reflected in the INCI list.
4. Bilingual label proof with identity, net quantity, ingredients and company contact.
5. Written agreement on who files the CNF and keeps it updated.
6. Stability and compatibility checked in the final pack.

Selling food or supplements too? Our article on supplement and protein powder co-packing in Canada covers the rules on that side.

Where COPACK Canada fits

COPACK Canada provides co-packing and packaging solutions for beauty and personal care brands as well as food, beverage and supplement brands, from Toronto and Vancouver. Share your product type, formula viscosity, container format and target volume when you request a quote, and we’ll tell you what we can take on.

FAQ

Sources

• Cosmetic Regulations, C.R.C., c. 869, sections 15.3, 18, 21.4 and 30 (laws-lois.justice.gc.ca)
• Health Canada, Notification of Cosmetics and Guide for Cosmetic Notifications (canada.ca)
• Health Canada, Industry Guide for the labelling of cosmetics (canada.ca)
• Health Canada, What is a cosmetic? and Cosmetic advertising, labelling and ingredients (canada.ca)
• Health Canada, Notification of Cosmetics: Examples of cosmetics and products not considered to be cosmetics (canada.ca)
• Health Canada, Product Assessment Against Criteria: Antiperspirants (canada.ca)

This article is general information, not legal or regulatory advice. Confirm requirements with Health Canada and a qualified regulatory advisor.