Q.01

What is Canada's Cosmetic Ingredient Hotlist?

Health Canada's Cosmetic Ingredient Hotlist is a list Health Canada uses to tell manufacturers and others that certain substances may be prohibited or restricted for use in cosmetics sold in Canada. It is an administrative tool, not a regulation, and it is not exhaustive. Each entry is either prohibited (the substance must not be in a cosmetic) or restricted (the substance is allowed only under the conditions listed).

Approach: I searched the Hotlist entries (English and French editions, current 2025 edition) and read Health Canada's official Hotlist pages on canada.ca.

Legal basis and status

  • Health Canada calls it "an administrative tool that Health Canada uses to communicate to manufacturers and others that certain substances may be prohibited or restricted for use in cosmetics."
  • It rests on section 16 of the Food and Drugs Act, which sets the general prohibition based on cosmetic safety, and on the specific prohibitions and restrictions in the Cosmetic Regulations. Health Canada also points to section 24 of the Cosmetic Regulations (labelling) and section 2 of the Act (whether a product counts as a cosmetic).
  • Because the list is not exhaustive, Health Canada can take enforcement action "regardless of whether a substance is included on the Hotlist." Manufacturers are expected to watch safety data themselves and act on risks they find, rather than "wait for a regulatory or Hotlist update."

What an entry contains

  • Prohibited entries give the ingredient name, CAS number(s) and synonyms. Some prohibited entries have no CAS number.
  • Restricted entries also give the conditions of use, maximum concentrations and any required label warnings. Two examples:
    • Hydroquinone (CAS 123-31-9) is restricted to three uses:
      • Hair-dye oxidizing colouring agents: up to 0.3%.
      • Nail products: up to 0.1%. If p-hydroxyanisole is also in the product, the two together "may not exceed 0.1%".
      • Cyanoacrylate adhesives for eyelash and eyebrow extensions: up to 0.1%.
      • Required warnings include "Avoid skin contact" and "Do not use to dye eyelashes or eyebrows" [1].
    • Formaldehyde (CAS 50-00-0) is not permitted in aerosols. Its limits by use are:
      • Non-aerosol products that release formaldehyde vapours when used as directed: 0.01%.
      • Oral products: 0.1%.
      • Non-oral products, as a preservative: 0.2%.
      • Nail hardeners: 5.0%, and they "must be sold with nail shields and directions for use" [2].
  • Size: the current English edition, last modified 13 August 2025, has 490 prohibited and 90 restricted entries.

How it is updated Health Canada lists these steps:

  1. A Notice to Stakeholders, with 3 months' advance notice.
  2. A public consultation with a 60-day comment period.
  3. Review of the comments.
  4. Publication of the updated Hotlist and notice to stakeholders.
  5. Compliance promotion and enforcement.

Health Canada keeps a separate page listing past changes.

Sources:

Q.02