Enhanced requirements for cosmetic notifications
From March 2025, every new Cosmetic Notification Form (CNF) submitted to Health Canada must include a valid Canadian address. Without it, notifications will no longer be accepted. This update reinforces existing regulations while addressing confidentiality concerns for foreign brands.
While Canadian importers and manufacturers were already required to submit a notification 10 days after they first sale a cosmetic product in Canada, the 2024 regulatory amendments introduced new obligations. Importers may now be required to provide evidence of safety within 10 days if requested by the Minister. Notably, to protect proprietary information, third parties (Canadian Agent) can submit this evidence directly to Health Canada on behalf of the importer or manufacturer. This ensures sensitive data remains confidential while maintaining full compliance, particularly when no importer or Canadian manufacturer is identified in the CNF.
These changes make the role of a Canadian Agent indispensable for ensuring smooth and compliant market access. EcoMundo provides tailored support to navigate these evolving requirements while safeguarding proprietary information.
A liaison between brands and Health Canada
The Canadian Agent serves as the official point of contact between the brand and Health Canada. Unlike the Responsible Person in Europe, this agent holds no responsibility for product safety. Its role is primarily administrative, including:
- Submission of Cosmetic Notifications: The Canadian Agent can submit Cosmetic Notification Forms (CNF) for each product marketed in Canada.
- Official Contact Address: The agent’s name and address appear in CNF declarations, though they are not required on product labels. It is important to note that Canadian regulations do not mandate a Canadian address on labels. Instead, labels must include:
- The identity and principal place of business of the manufacturer or distributor.
- For primary packaging, contact information for product-related questions, such as a telephone number, email address, website, postal address, or any other means for consumers to inquire about the product.
- Liaison with Health Canada: The agent facilitates communication in case of information requests or audits.
Although the Canadian Agent is not responsible for product safety, EcoMundo can act as your Canadian Agent while also supporting your compliance efforts through formula, label, and claim reviews, alongside adequate safety evidence. Their extensive experience with the Canadian market ensures that your products meet all regulatory requirements seamlessly.
Who needs a Canadian Agent?
Any foreign brand aiming to market cosmetic products in Canada is subject to this requirement, including manufacturers, distributors, and private-label brands. Without an address in Canada, it will no longer be possible to complete the notification process with Health Canada.
Who can be your Canadian Agent?
The Canadian Agent must be a legally established entity in Canada. This can be a business partner, distributor, local subsidiary, or specialized service provider. The primary requirement is their ability to fulfill Health Canada’s administrative obligations and act as an official contact for regulatory communication. EcoMundo, through its Montreal-based subsidiary, offers Canadian Agent services, providing comprehensive support to ensure your products meet regulatory requirements.
Impact on new notifications from 2025
Until March 2025, existing notifications remain valid without updates. However, from that date onward, every new submission must include a valid Canadian address to be accepted by the authorities.
Want to learn more?
EcoMundo is hosting an exclusive webinar on March 13, 2025, to break down the latest regulatory changes affecting the Canadian cosmetic industry.
From the pivotal role of the Canadian Agent to Quebec’s Loi 96, their experts will guide you through the essential steps to ensure product compliance and answer any questions you may have.
👉 Register now to secure your spot: https://form.ecomundo.eu/en/webinar-canadian-agent
