Cosmetic Notification Forms (CNF) – Part Two

Wow, this month is flying by! I apologize for the delay in getting Part Two of this series on CNF published, especially since I know it is on the mind of so many of you these days.

In the first part of this series we talked about what a CNF is, and when you would need to file one. If you missed it, you can find it here. Today I’m going to talk a little bit about completing the actual filing process. A blog is not a good forum to actually walk through completing a form step by step, so I’m going to answer Frequently Answered Questions in this post.

The first thing to know is that there is no fee for filing a CNF with Health Canada.

Secondly, when you sit down to file your first one, it’s going to look really confusing; don’t panic, it’s really not that bad.

To file a CNF you will need to go to this link for English, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-eng.php, or this link for French, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-fra.php. Before you start actually filling out the form, I would suggest that you either print or download into another window the Guide to Filing Cosmetic Notification Forms, which is found here in English, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/guide-eng.php, and here in French, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/guide-fra.php.  This Guide will walk you through the steps to completing a CNF, and should make the process relatively painless, but if there continues to be confusion surrounding the process, let us know and we can put together a step by step tutorial. 

Questions:

1) Am I the Notifier, the Manufacturer or the Distributor?

The answer to this is sometimes you’re all 3! It depends on how you sell your product. If you are making product and selling it directly to the public, you are the Notifier (the company that is filing the form), the Manufacturer (the company that is making the product) and the Distributor (the company that is selling the product).

If you are selling product to stores at wholesale prices and they are selling to the public, you are the Notifier and the Manufacturer, and the store(s) would be listed as the Distributor. This also applies if you are making products for Private Label customers. You would have to file 1 CNF for your direct sales to the public, then file a separate CNF for each retailer or Private Label customer that sells your product.

2) What is a Notifier’s Reference and do I have to have one?

This is a description you use to identify a product for your own use. If you make Lavender Soap, you might use that description on your website, but for selling you may have an SKU identifier, such as SPLAV or maybe a number that identifies it on your system. You don’t have to enter this on the CNF form unless you want to.

3) Do I have to file a separate CNF for each different fragrance of a product?

If the manufacturer, distributor, function, and form of the cosmetic are the same for all the variations of the product, and the base ingredients remain the same, you can file one CNF and add all of the variations in colour, fragrance, or flavour by using the “May Contain” option. If you sell wholesale and/or Private Label as well, you would have to file 1 CNF for your direct sales to the public, and a separate CNF for each store or Private Label customer that sells your product.

4)  Do I list the exact percentage of that I use of each ingredient?

No. The reason for listing the ingredients is so that Health Canada can confirm you are not using ingredients that are prohibited from use in cosmetics, or if they are permitted but restricted, you are using a safe percentage. They do not need to know what your exact recipe is. If you use 20% shea butter in your lotion, you can use any range that contains your 20%. For instance, LL (Lower Limit, or the minimum that you would use) of 10% and UL (Upper Limit, or the maximum that you would use) of 40%. As long as your recipe stays within the ranges you list for each ingredient, you won’t have to file an amendment if you adjust your recipe slightly because you were short on shea butter and added a little more cocoa butter instead. NOTE: that only applies if all of the ingredients remain the same, and the amount you use falls within the range you have listed on your CNF. You cannot substitute ingredients without filing a new CNF.

5)  I only use fragrance oils in my products; how do I fill out the CNF for that?

If you make a product where the base is always the same, but you use multiple different fragrance oils, you file one CNF and you list your fragrance oils as “Parfum”. If you make some with fragrance oils and some with essential oils, you can still file one CNF, but use the “May Contain” option to list all of the options, including one for ‘Parfum”, and one for each different essential oil.

6)  When I’m listing my ingredients for soap, do I list what goes into the pot, or what comes out of the pot?

The definition of ingredients for the purpose of filing a CNF “excludes ingredients consumed during the manufacturing process”. Since lye is used up during the soapmaking process, the proper way to list the ingredients is by using the INCI for the soap that is produced. For instance, saponified olive oil is sodium olivate, saponified coconut oil is sodium cocoate, etc. You can find an INCI listing in the Files of our Facebook group Soapz and Stuffs.

NOTE: Although glycerine is created during the soapmaking process, you do not add it to your ingredients. The definition of ingredients for the CNF is “any substance or component that is deliberately added to the formulation.” Glycerine is created during the process, not added. Please note that you DO need to add it to your label. 

7) Ok, I’ve got my number now what?

Once you’ve filed your CNF, you may receive an email or telephone call asking you to change or clarify some information. If you don’t receive any questions, at some point you will receive an email or letter containing your Cosmetic Number. File it away in a safe place. If you change your recipe, or discontinue selling the product, you will need that number to file an amendment to your CNF. You will also need to have it to show to Health Canada inspectors who may show up at a market where you’re selling, or may find you online.

8) I’ve changed my recipe, now what?

Anytime you make a change to your recipe that increases or decreases an ingredient so that it no longer falls within the range listed on the approved CNF, you will need to file an amendment. You will also need to file an amendment if you make an existing product but use a new essential oil. You don’t need to file an amendment to add a new fragrance oil or flavouring, because the generic “parfum” and “flavour” used on your original CNF will still apply.

Okay, those are the FAQs that we see most often. If any of these answers are unclear, or you have other questions, please feel free to leave a comment below, and I will answer as quickly as possible. You can also post a question in our Facebook group, as we have many people there who are experienced in filing CNFs and would be happy to help.

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13 Responses to Cosmetic Notification Forms (CNF) – Part Two

  1. Kayla Erskine October 18, 2016 at 5:47 am #

    Thank you so much for this! I am new to this and its so hard to find someone to talk as everyone seems to be so competitive. I was wondering , manufacturing your product in your home , is that allowed for hand crafted items or do you have to rent a licensed kitchen such as one in a hall etc? I could not find any information on that. Also, the CNF is the only form we need to fill out for our bath products? Thanks

    • Marg October 18, 2016 at 6:00 am #

      Hi Kayla

      The process can be confusing, I’m happy you found it helpful.

      In Canada, you are allowed to make handcrafted bath and body products in your kitchen, however you should also doublecheck with your municipality to make sure there are no bylaws that prohibit this.

      The CNF is the only documentation you need to register with Health Canada, however you do also have to comply with all Health Canada labeling laws for cosmetics.

      If you have any questions, you can always find answers in our public Facebook group, Soapz and Stuffs.

      See you in the groups!

      Marg

  2. Karen November 12, 2016 at 12:28 pm #

    Thank you very much for walking a new member such as myself through this maze. This past year I have had the best time ever formulating and testing products but I now find myself ready to sell on a small scale but its been beyond overwhelming to set up ingredient labelling and I am about to bravely embark on my filings. I had decided to list my oils for my cp soaps in the saponified form and your comment regarding adding glycerin to the ingredient list caught my attention. Without testing for an accurate glycerin percentage where would it be appropriate to place on my ingredient list? Would I list it directly after the oils?

    Many thanks in advance for your reply and thanks again for a very helpful post 🙂

    Karen

  3. Pauline June 10, 2017 at 7:50 pm #

    Hello Marg

    My son has recently filed a CNF for essential oils that we are making for the purpose of selling as beard oils. We would like to buy insurance through HBBG but cannot do this till we receive our number from the CNF. Can you tell me how long this should take. He filed near the beginning of May.

    Thank you

    • Pauline June 12, 2017 at 3:04 pm #

      Thank you for your quick response. It’s so nice to know that there is someone out there ready and willing to help. 🙂

  4. Stephanie June 12, 2017 at 6:19 pm #

    Hi!

    This information is so helpful but recently I received some information that sent me into panic mode. I see you can simply list May Contain. For the various fragrance or essential oils. However I was recently told that health Canada has new rules that state that any product containing any amount of essential oil is now considered a natural health product. That would require an enrely different application and rules for production.

    Do you have any concrete information regarding this? Is it true that we cannot use essential oils now in any form within a natural health product license?

    Any information, advise or direction would be most appreciated.

    Thank you in advance!

    • Marg Peebles June 13, 2017 at 7:40 am #

      Hi Stephanie As of this moment there are no such restrictions on essential oils. Health Canada is currently undertaking a review of cosmetic regulations, and there may be changes in the future, but there is no telling what those changes may be. We monitor Health Canada closely for any changes that affect our members, and will be sure to publicize any information as we receive it on our blog, our Facebook page, and our non-member Facebook page, Soapz and Stuffs. As long as you are signed up to one of these, you will see any posts regarding new Health Canada regulations.

  5. PaFu June 16, 2017 at 4:38 pm #

    Hi , this is a very useful article
    I am trying to regiester for cosmetics in Canada ,
    If my company falls into “distrubitor, importer and manufactuer” which one of those should I select on the form?
    Also for the secion “other product name ” , should i add all of the products I want to sell.
    We sell different product category and shades.

    Thanks so much!

  6. Nesly Minas June 18, 2017 at 6:21 pm #

    Hi there! I’m so happy I found your blog! It really has helped to solve many questions I am an importer of Asian beauty products and now im in the process of filling my forms, the only problem is that I but my products from side suppliers that work with the manufacturers and they won’t supply me their ingredients concentrations/percentage due to their formula privacy . The only information they gave me was their concentration goes from highest to lowest so in this case I’m trying to find if health canada has a cosmetic data base for me to follow? Any recommendations are welcome since we are a little stress here . Thanks in advance

  7. Wendy June 19, 2017 at 5:34 pm #

    Hello, Thanks for this information! I have a question regarding the filing of each individual soap I make. I currently have about 7 different recipes that I want to sell, with varying amounts of essential oils. If I understand this correctly, I will need to file 7 different CNF’s. So companies (like Lush for example) that sell a large variety of product have to file a separate CNF for each product if they have different oils or essential oils? I just want to be clear. If I am understanding it right, then I would have my recipes next to me and file a form for each recipe, correct?
    thanks!

  8. Ashley August 9, 2017 at 3:30 pm #

    How do you know if your product has been approved? Do they send you something? And what is the typical timeline for that?

  9. Marilyn Cox October 5, 2017 at 6:28 pm #

    Hi! I was wondering if anyone had tried submitting oakmoss absolute ( Evernia prunastri) in the ingredients field on the NOC form? It comes up as unknown for both the common and inci name and yet it is a not uncommon fixative for perfumes/scent. Not sure what to do if an ingredient comes up unknown on the form! HALP!

  10. simona October 11, 2017 at 5:34 pm #

    Hi. Please help to make this clear. I filled my CNF , now I have to wait for their number. Is there anything else I should do in order do comercialise my products? Products been labelled, sealed. What any other conditions should be followed?
    Can I sell the products while I am waiting for CNF number?
    Thank you!

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