If you decant bulk product into your own bottles and put your salon name on the label, you are no longer just a reseller. Under Canada's Cosmetic Regulations you become responsible for that product. Two obligations follow: your label has to carry specific information, and you have to notify Health Canada.
Before you close this tab: it is one form. And it is free.
Take a breath first
I regularly watch technicians back away from buying bulk because of this step. The word regulation makes people think of lawyers, inspections and fines. So let us put it in proportion right away.
- It is not an approval. Nobody evaluates your product, nobody judges your formula, and nobody can turn you down. You declare that a product exists, what is in it, and who to contact. That is all.
- No lab testing is required for a standard cosmetic. You have nothing to send away for analysis.
- Nobody comes to your salon. There is no inspection attached to this.
- It is not set in stone. Change supplier, size or name? You amend the notification. There is a form type for exactly that.
- It is once per product. Not per batch, not per year, not per client.
An organised technician clears the whole thing in one afternoon and never thinks about it again. The longest part is waiting for your supplier's email.
1. Does this apply to me?
Yes, if you fill your own bottles from bulk, put your own brand on a product, or sell any cosmetic to a client. Using a product on a client during a service is not selling. Handing her a bottle in exchange for money is.
2. The Cosmetic Notification Form
Health Canada requires sellers of cosmetic products to notify within 10 days after the first sale of a cosmetic in Canada. Again: it is a notification, not an approval.
What the form asks for:
- Whether this is a new notification, an amendment, or a discontinuation
- Product name and brand
- The full ingredient list in INCI, with exact concentrations or concentration range codes
- Where on the body it is applied, and what it does
- The form of the product: liquid, gel, foam, powder
- Contact details for the notifier, the manufacturer and/or the importer
Which document to ask your supplier for
The concentration ranges are the part that stalls beginners. Your bulk supplier has them. Every professional supplier knows this request, and it is the same in the United States.
Ask for an ingredient disclosure sheet, or an INCI statement with concentration ranges. That is the document that contains exactly what you need.
You may instead be offered a Safety Data Sheet. Keep it, it is useful for storage and handling, but it usually will not be enough on its own: an SDS only declares components considered hazardous. For a mild lash cleanser, the ingredient section can be nearly empty. If that is all you receive, ask again for the full list. It is a routine request and nobody will find you difficult.
3. What has to be on a Canadian label
Canadian cosmetic labelling sits at the intersection of the Cosmetic Regulations and the Consumer Packaging and Labelling Act. The mandatory elements:
- Product identity, in English and in French.
- Net quantity in metric units.
- Name and address of the dealer, meaning whoever is responsible for the product in Canada. That is you if it carries your name.
- Ingredient list in INCI, descending order of concentration.
- Warnings and safe use directions where the product requires them, in both official languages.
You do not have to print your home address
This is the question that comes up most often, and the answer puts a lot of minds at rest. The requirement is that the address allows postal delivery to your principal place of business. Not a storefront, not street frontage.
A Canada Post box or a mailbox at a UPS Store therefore works perfectly. If you work from home, that is the route to take: your bottles travel, and you do not want your personal address circulating in handbags around town.
It is an annual cost that varies by box size and location, so check the rates near you. It is the one genuinely unavoidable expense in this whole process.
What does not work: a postal code on its own, or a phone number or email address in place of an address.
The bilingual requirement is the one most people miss. Mandatory label information has to appear in English and in French. The good news: INCI is a single international nomenclature, so your ingredient list does not need translating. It is the product identity, the warnings and the directions that do.
Check the Hotlist first
Health Canada publishes a Cosmetic Ingredient Hotlist of substances that are prohibited or restricted in cosmetics sold in Canada. Before you commit to a formula or a supplier, run the ingredients against it.
The good news is that most products made recently by a Canadian laboratory are already compliant. An imported product with no documentation is another story entirely.
4. Cosmetic or drug?
In Canada, a claim that a product changes the structure or function of the body pushes it out of the cosmetic category and into drug or natural health product territory, which means a DIN or an NPN and a completely different process.
Safe territory: moisturising, conditioning, nourishing, helps improve the appearance of lashes.
Problem territory: grows lashes, regrows, treats blepharitis, eliminates bacteria, heals.
This applies to your social media captions too, not only the bottle.
5. The real time and the real cost
- Ask your supplier for the INCI list and concentration ranges: one email
- Design a bilingual label: varies, depending on whether you build it yourself from an editable template or hire a designer
- Fill out the Cosmetic Notification Form: 30 to 45 minutes for a first product, much less afterwards
The costs: the notification itself is free, in Canada and in the United States. Budget for a mailbox if you would rather not display your home address, and for a designer if you do not want to touch the template yourself. Nothing else costs anything but your afternoon.
6. The mistakes I see most often
- An English-only label. It is by far the most common compliance gap in Canada, and even more so in Quebec, where French is non-negotiable.
- Not notifying at all, because nobody ever mentioned that Health Canada notification existed.
- Saying "Health Canada approved" after filing. No cosmetic is approved by Health Canada. You receive a number confirming the notification was received, and that is all. The only beauty products that get approved are drugs and natural health products, and those carry a DIN or an NPN clearly on the front of the label. That is not what we are dealing with here.
- Using the supplier's marketing copy without checking the claims.
- Copying and pasting the supplier's ingredient list instead of the real INCI. Very common with imported products.
- A perfectly legal label undermined by a growth claim in a caption.
What if nobody ever asks?
Honestly? In over ten years, very few clients have ever asked me for my INCI list or my documents. That does not make the exercise pointless.
The day a client reacts to a product, or an esthetician wants to carry your line, or a salon wants to buy your brand, or someone asks a pointed question in front of other people, you are the one who answers in thirty seconds instead of the one who goes looking. That difference is what your afternoon buys you.
And in reverse: when you are shopping for a supplier and they cannot produce these documents, you have just learned something important about them.
Need a hand?
I have been supplying lash professionals for over a decade and I have filled out these forms many times. If you get stuck, write to me at contact@secretsid.com and I will help. No charge. I would rather you do it properly than not at all.
This article is general information, not legal or regulatory advice. Requirements change. Confirm the current rules with Health Canada before you rely on anything here.