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.
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
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
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
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
Thank you for your quick response. It’s so nice to know that there is someone out there ready and willing to help. 🙂
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!
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.
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!
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
Hello Nesly, I would like to know if you have found a solution to the problem, because I have the same situation now. I plan to import Asian products, but no one gives information on the concentration of ingredients.
I’ve been having the same exact problem and now I’m stock! Companies are not willing to give out their ingredients concentration and in the CNF form, it’s required to enter the concentration. Is there any wary around this issue??? Please if somebody knows, let us know. We are stock right now.
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!
How do you know if your product has been approved? Do they send you something? And what is the typical timeline for that?
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!
Hi Marilyn If an ingredient is coming up as ‘unknown’, you can contact Health Canada and ask for assistance.
Thanks Marg! I did as you suggested and they replied (a bit grumpily!) . Their online form really needs a suggested input feature when entering ingredients. Felt like I was plunking away on an old typewriter so very unintuitive and non-interactive.
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!
Hi. I make a face cream and I use a base cream that I purchase from a company in Alberta. I add 4 oils to it, camellia oil, rice bran oil, rosehip seed oil and jojoba oil. I want to fill out a CNF form for it, but It asks if I manufacture it. Do I need to list the manufacturer as the company I purchase it from and then add the additional ingredients that I put into it and say I’m the nmanufacturer/ I’m finding this very confusing.
Hi Vicki If you are adding ingredients to the base, then you need to put your company as Manufacturer and list all of the ingredients in your finished product, including the ingredients that are in the base. Marg.
Thank you for this as it is very helpful.
i am a bit confused on colours. I use Mica and food colouring depending on the type of product. How do I list colours – also do I list the colour for each product or fragrance?
Is there link in which I can print or apply for this form online?
Hi Railynn
The link to the Health Canada Cosmetic Notification Form is in the post above, in both English and French, as well as a link to the Guide to completing the form.
Hi,
This article has been so helpful, thank you.
I’m also wondering about previous poster’s question on the timeframe of receiving the CNF number from Health Canada and also if I’m able to sell prior to receiving it?
Hi Harmony The time frame for response back from Health Canada fluctuates depending on how many people are filing at the same time as you, but don’t be surprised if it is a few months. The good news is that you can go ahead and sell while you wait. The regulation states that you must file a CNF within 10 days of first sale.
Hi, what if I would like to sell to customers in US? Does the law differ in any way?
Thank you
hi i am trying to fill my Cosmetic Notification form for bath booms i list all my ingredient but when i enter citric acid at Concentration of 2 i got (Restricted) what should i do
So glad i found this site! i have filled out and been approved by health canada but my question i have is i want to add propylene glycol. sorbitol stearic acid lauric acid to my recipe. on the soap blog they say it is an additive and don’t need to include on the notification form where do you add these 4 ingredients and if so do you add the amount
also where is purfume on the form? again thanks for taking the time to reply
one more question ha ha i buy melt and pour soap and i want to make a travel soap sheet. how do you calculate all the ingredients listed on the label of the melt and pour . and how do you fill out the notification form with what is one the label as amounts are not listed as it has to be 100
again that’s all i have so many thanks
Hi I want to change the name of my product and add some other ingredients. Where do I enter the new product name? There are instructions about adding new descriptions but this is a label change.
Thx Liz
hello…
I filled up a CNF and it was rejected saying the claims i made was outside the purview of it being a cosmetic product. I have revised the claims and it now falls within the definition of a cosmetic product. Do I submit a new CNF or an amended CNF? I wasnit given a cosmetic notification number.
Thanks in advance for your helpful suggestion.
Hi…this may be a silly question but is the CNF filing required if you are not selling, At this point I’m gifting but have no plans to sell. I belong to a forum that says gifting and selling is the same as it relates to the government and that a CNF filing is required. I’ve looked everywhere but I can only find reference to selling. I will go through the process if required but don’t really want to if it isn’t necessary.
Thanks for the feedback.
Health Canada Regulations state that a label on the product has to be the same as what is submitted to them, so ingredient labels should only list ingredients as the soap produced? For example a label listing Olive Oil, Coconut Oil etc. is incorrect unless it is listed as Sodium Olivate, Sodium Cocoate etc.
This has probably been asked but wanting update comment, If I have Filed my CNF can I sell in retail stores while I wait for my Number?
Hi there, I have question in about insurance. If I just filed the CNF(have case number), and didn’t have the cosmetic number yet. Is the insurance cover my products? Or they just cover the products that have cosmetic number? Thank you!
Hi there, if my base ingredients are the exact same and the only things that change are the fragrance/EO and the botanical I add to it (example, lavender bulbs or chamomile flowers, etc.), do I need to provide a separate CNF form? Thanks so much!
Hi
I recently submitted my CNF to Health Canada. Do you have any idea how long it will to hear back from them? And also Am I allowed to sell it or I really need to wait for the feedback about my CNF submission? Thank you in advance.
Thank you for your accurate and helpful information. I wanted clarification on how to list the soap ingredients. A couple of other websites stated that you must calculate the glycerine. That felt wrong to me after reading the Government’s webpage on how to fill out the Cosmetic Notification Form.
Hi there, does anyone know how infusion oil is added to a CNF form ?( Olive oil infused with Calendula)
please forgive me if this has already been answered
thank you so much 🙂
I am loooking for this too !!
I came looking for the exact same answer, but since the original post was 2 years ago, and the secondary post was a year ago with no response, I will hope for an answer but keep looking elsewhere.
Help! I am trying to add my cosmetic colourants using the IC number, and sometimes there are 4, or more.
Didn’t work. Tried using the name of the Mica, and did not accept.
Driving me crazy!!!!! It is the last step so I can submit my form, so any direction would save my sanity.