The Infamous Cosmetic Notification Form (CNF)
Not Approval. Not a License. Just a Legal Obligation.
The real purpose of the cosmetic notification form
The Cosmetic Notification Form (CNF) system in Canada is a notification-based framework, not an approval process.
Here’s the breakdown:
When You Submit a CNF:
You’re not asking Health Canada to “approve” your product.
You’re informing them that you are selling a cosmetic product in Canada.
Health Canada records it in their system.
You’ll get a notification number, but that number does not mean your product was reviewed, approved, or verified.
What That Means for Makers:
Health Canada assumes that you’ve:
Checked your formula against the Hotlist (and that it complies).
Used proper INCI naming.
Filed the correct product type (cosmetic vs. NHP or drug).
Followed all applicable labeling rules and bilingual requirements, and
Avoided false or misleading claims (especially therapeutic ones).
Health Canada is Reactive!
This means they will only act after the fact:
If they spot-check or are alerted to a product (e.g., by a consumer, retailer, customs, or inspector).
If a complaint is filed.
If they run a targeted compliance sweep (like they do for certain product types—e.g., SPF, acne, baby care, etc.).
Why This Matters:
This setup creates a false sense of safety for some founders.
They think:
“I submitted my CNF and got a number — I must be good to go!”
But if you didn’t properly check the Hotlist, or you made claims that tip into drug territory, or your label is missing a bilingual element.
📌 You’re still legally responsible.
From The Indie Guide to Cosmetic Compliance in Canada, pages 74-75