Exporting Cosmetics to Canada: CNF, Hotlist, Labels, CBSA and Duty

Cosmetic, drug or natural health product?

Canada regulates cosmetics, drugs and natural health products (NHPs) under the Food and Drugs Act, and the class depends on the ingredients and the claims. Therapeutic claims, such as treating acne or preventing a disease, are allowed only on drugs and NHPs. These need a Drug Identification Number (DIN) or a Natural Product Number (NPN) before they are imported for sale, and the Canadian importer needs a drug establishment licence (for DIN products) or an NHP site licence (for NPN products) that lists the foreign manufacturing site.

All sunscreens sold in Canada need a DIN or an NPN, depending on their active ingredients. This includes products where sun protection is a secondary function, such as foundations, tinted moisturisers and lip products with SPF, which follow Health Canada's secondary sunscreen monograph. A BB cream or cushion that claims an SPF therefore cannot be sold as a cosmetic.

Other products at the cosmetic-drug interface include anti-dandruff products, acne treatments, fluoride anti-cavity toothpaste, medicated skin care, diaper rash products, antiseptic skin cleansers and skin or tooth whiteners; check Health Canada's classification guidance for each. Antiperspirants differ from the US: most are cosmetics in Canada, within set limits for aluminium salts, unless they are intended for hyperhidrosis or claim to modify a body function.

Cosmetic Notification Form (CNF): who files and when

Under sections 30 and 31 of the Cosmetic Regulations, every manufacturer and importer must notify Health Canada at the latest 10 days after it first sells a cosmetic in Canada. The CNF is filed through Health Canada's online form, with no fee. A notification number is not an approval, and it does not mean Health Canada agrees that the product is a cosmetic.

Amendments in force since 9 October 2024 (SOR/2024-63) define the manufacturer as a person in Canada who sells the cosmetic under its own name or mark, or a person in Canada authorised to act for someone outside Canada; the importer is whoever imports the cosmetic to sell it. Since 5 March 2025 the form requires a Canadian address for the manufacturer or importer. A foreign brand therefore notifies through its Canadian importer or distributor, or through a Canadian agent it authorises; a consultant may fill in the form, but the Canadian party's details go in section 4.

• One CNF can cover shades, scents or flavours of the same base formula sold under the same name.
• Ingredients are given by INCI name in one of 13 concentration ranges, and the form states whether the product is leave-on or rinse-off and which fragrance allergens are above the disclosure thresholds. Giving their exact concentration is encouraged but optional for most allergens.
• File a revised CNF within 10 days after any information becomes inaccurate, for example a change in formula (ingredients or concentrations), product name or contact details, and notify Health Canada when you stop selling the product.
• Selling a cosmetic that has not been notified is prohibited. Health Canada can request more information, to be supplied within 10 days, and evidence that the product is safe; products can be refused entry into Canada or removed from sale.

The Cosmetic Ingredient Hotlist and other ingredient bans

The Cosmetic Ingredient Hotlist is Health Canada's administrative list of substances that are prohibited or restricted in cosmetics. It applies the general prohibition in section 16 of the Food and Drugs Act on selling a cosmetic that may injure the user. Prohibited ingredients should not be present at all; restricted ones are allowed only within the stated concentrations, product types and cautionary statements. The CNF form shows each ingredient's Hotlist status, and shipments with Hotlist problems may be refused entry or removed from sale.

Recent changes: in May 2024 Basic Green 4 was prohibited and benzophenone and p-chloro-m-cresol were restricted; in February 2025 retinal was added as restricted, thioglycolic acid esters were prohibited, the limits for retinol and its esters were lowered for some products, such as body lotions, and benzoyl peroxide was limited to professional nail products; in August 2025 the cannabis entries were amended. A consultation from 19 November 2025 to 17 February 2026 proposed restricting Basic Violet 4, Basic Blue 7 and polyaminopropyl biguanide (PHMB, which would be banned in sprays), prohibiting brucine and changing the Symphytum (comfrey) and furocoumarin entries. Check whether the revised Hotlist has been published before you finalise a formula.

Separately, the Microbeads in Toiletries Regulations ban the manufacture, import and sale of toiletries used to exfoliate or cleanse that contain plastic microbeads, meaning plastic particles of 5 mm or less.

Labels: English and French, INCI names and fragrance allergens

Cosmetic labels must meet the Cosmetic Regulations and the Consumer Packaging and Labelling Act. All required information must be in English and French, except the ingredient list.

• Product identity, by common name or function, in both languages, unless it is obvious, as for a lipstick.
• Net quantity in metric units on the principal display panel of the outer label; metric symbols such as g and mL count as bilingual.
• Dealer: the name and principal place of business of the foreign company, or of the Canadian dealer preceded by "imported by / importé par", plus contact information (phone, email, website or postal address) for consumer questions.
• Ingredient list on the outer label, or on the only label, using INCI names in descending order of concentration; ingredients at 1% or less and colourants may follow in any order. Very small packages may use an attached tag, tape or card, or a website named on the outer label.
• Fragrance allergens: listed by name, outside "parfum", when above 0.01% in rinse-off or 0.001% in leave-on products. Canada uses the allergens in Annex III of EU Regulation (EC) No 1223/2009: 24 since 12 April 2026, and 81 for new cosmetics from 1 August 2026 and for existing products from 1 August 2028.
• Warnings and directions for safe use in both languages, including Hotlist cautionary statements and the required symbols and warnings on pressurized containers.
• Quebec: since 1 June 2025, under the Charter of the French Language, a trademark in another language may stay untranslated only if it is registered and no French version is registered, and generic or descriptive words in it, such as cream, scent or colour, must also appear in French.

Customs clearance: Business Number, CARM and invoices

The importer of record needs a nine-digit Business Number (BN) from the Canada Revenue Agency and an import-export (RM) program account. Since 21 October 2024 the RM account is opened and managed in the CBSA Assessment and Revenue Management (CARM) Client Portal, where the importer also delegates authority to its customs broker, who files the release and the Commercial Accounting Declaration (CAD).

Release prior to payment (RPP) requires the importer's own financial security posted in CARM, sized on its highest monthly duties and taxes; a broker's security could be used only until 20 May 2025. Without RPP, duties and taxes must be paid at a CBSA office before the goods are released. The CBSA accepts a Canada Customs Invoice (form CI1) or a commercial invoice in English or French with the same information (Memorandum D1-4-1). Import records must be kept for six years, and CBSA officers may detain cosmetics they suspect do not comply with Canadian law.

A foreign company can be the importer as a non-resident importer (NRI): it gets a BN and RM account, registers in CARM, posts its own RPP security and normally uses a Canadian customs broker, and it must keep records in Canada, or have an agent there keep them, unless the CBSA authorises another location. Being the importer also brings the Health Canada duties, and the CNF still needs a Canadian address, so an NRI brand also needs a Canadian agent for the notification.

Duty, free trade agreements and GST

Perfumes (3303), make-up and skin care (3304), hair products (3305) and shaving, deodorant and bath products (3307) have a 6.5% most-favoured-nation (MFN) rate in Canada's 2026 Customs Tariff. They are free for goods that qualify under a free trade agreement, including the Canada–Korea FTA (CKFTA, in force since 1 January 2015), the CPTPP (for example Japan, Vietnam, Malaysia and Singapore), CUSMA (US and Mexico), CETA (EU) and the Canada–UK agreement. China and India have no FTA with Canada, so their cosmetics normally pay 6.5%. Canada's 2025 counter-tariffs on US goods were removed for CUSMA-compliant goods from 1 September 2025, but since 8 September 2026 Canada has again charged counter-tariffs of 15%, 25% or 50% on a list of US-origin goods that includes cosmetics and personal care products, so check the list for US-made products.

To claim a preference the importer needs proof of origin: for CKFTA a certificate of origin completed and signed by the exporter (form BSF760); for CPTPP and CUSMA a certification of origin by the exporter, producer or importer, in no prescribed format. A certificate can cover one shipment or identical goods for up to 12 months and is valid for four years. For commercial imports with a value for duty of CAD 3,300 or less no certificate is needed, but the importer must keep records proving origin.

The CBSA collects 5% GST on the duty-paid value at import. In harmonized sales tax (HST) provinces, the provincial part on commercial goods is generally self-assessed on the importer's GST/HST return rather than paid at the border. An importer registered for GST/HST can recover the tax as an input tax credit; an unregistered non-resident importer cannot. This is practical guidance, not legal advice; confirm with Health Canada, the CBSA or a licensed customs broker.