Canada’s Cosmetic Ingredient Hotlist: what’s banned, what’s limited

Canada doesn’t approve cosmetics before they’re sold. So how does Health Canada keep mercury out of face cream, or stop a hair product from containing too much of a harsh chemical? A big part of the answer is a long web page with a slightly dramatic name: the Cosmetic Ingredient Hotlist. Here’s what it is, what’s on it, and what it can’t do.

What the Hotlist is

Health Canada calls the Hotlist an administrative tool it uses to tell manufacturers that certain substances may be prohibited or restricted in cosmetics. It isn’t a separate law. It’s a public list that links each entry back to rules that already exist, mainly the general ban in the Food and Drugs Act on selling a cosmetic that may injure the person using it, and labelling rules in the Cosmetic Regulations.

That legal link matters. Because the underlying rules are already in force, a new Hotlist entry applies as soon as it’s published. There’s no legislated grace period, though Health Canada says it focuses on helping companies comply after an update.

The list has two tables:

• Prohibited: the substance shouldn’t be in a cosmetic at all.
• Restricted: it’s allowed only under conditions. Those can be a maximum concentration, certain product types only, a pH range (how acidic the product is), or a required warning on the label.

A few real examples

Some entries are what you’d expect to see banned:

• Mercury and its compounds are prohibited.
• Lead and its compounds are prohibited.
• Chloroform is prohibited.

Many more are restrictions, and they show how the list thinks about dose and use:

• Salicylic acid, the beta hydroxy acid in many exfoliating products, is capped at 2%.
• Alpha hydroxy acids such as glycolic and lactic acid are allowed in consumer products between 3% and 18% (counted together), at a pH of 3.5 or higher.
• Retinol and its esters (vitamin A forms) are limited to 0.2% retinol equivalents in leave-on body products and 1.0% in other cosmetics.
• Methylisothiazolinone, a preservative, is prohibited in leave-on products and limited to 0.0015% in rinse-off ones.
• Formaldehyde is banned in aerosols, and capped at 0.2% when used as a preservative.
• Fluoride compounds aren’t permitted in oral cosmetics.
• Talc isn’t permitted in products meant only for the genital area, and has limits in loose powders to reduce how much people breathe in.

Notice the pattern. Many restrictions are about the line between a cosmetic and a drug. When azelaic acid was added in 2022, capped at 14%, Health Canada gave two reasons: its known therapeutic properties and its risk of skin irritation. The same reasoning applied to retinal, another vitamin A form, added in 2025. Above those levels, an ingredient starts to act like a treatment, and treatments go through drug review instead.

How the list gets updated

Health Canada says proposed changes draw on scientific journals and other evidence, decisions under the Chemicals Management Plan (Canada’s program for assessing chemicals), market surveys, and the actions and opinions of regulators and expert panels in other countries.

The process has steps:

1. A notice to stakeholders, about three months ahead. Health Canada notes this isn’t the formal consultation.
2. The proposed changes are posted on canada.ca for a 60-day comment period.
3. Health Canada reviews the comments, which can take several months, then publishes the update.

Updates come at irregular intervals. Recent ones landed in August 2022, May 2024, February 2025 and August 2025. The May 2024 round, for example, added benzophenone and two colourants after government chemical assessments raised health concerns, and it tightened the talc entry. It also raised the alpha hydroxy acid limit from 10% to 18%, a reminder that updates can loosen a rule as well as tighten one.

What the Hotlist doesn’t mean

This is where people most often read too much into it.

“Not on the Hotlist” doesn’t mean “proven safe.” Health Canada says plainly that the list is not exhaustive. It can act against any cosmetic that may cause harm, whether or not the ingredient is listed. And it tells industry not to wait for a Hotlist update: manufacturers are expected to watch the scientific literature and safety data themselves and act when the evidence calls for it.

“Allowed” doesn’t mean “won’t bother your skin.” A preservative or fragrance ingredient can be perfectly legal and still cause an allergy in the people who are sensitized to it. The Hotlist sets limits for the population, not for your particular skin.

A limit isn’t a quality score. A product with 1% of a restricted ingredient isn’t “safer” than one with 2% if both are within the rule and suited to the use. The limits are ceilings, not targets.

The list only works on products that follow the rules. Health Canada uses the Hotlist when it reviews the ingredient lists companies must file for their cosmetics. Products sold outside that system don’t get checked. In a 2020 advisory, Health Canada warned about unauthorized skin lightening creams sold online and in shops that were found to contain mercury, high-strength hydroquinone and potent prescription steroids, with risks including blisters, scarring and thinning skin.

What happens when a product breaks the rules

When Health Canada finds a Hotlist substance in a cosmetic, it has several options. It can ask for labelling to confirm the product meets the rules, ask the company to commit to fixing the product, ask for evidence the product is safe as used, or stop its sale or distribution.

If you think a product contains something it shouldn’t, or you’ve had a reaction to one, you can report it to Health Canada. And if a skin problem doesn’t settle after you stop a product, see your doctor or pharmacist.

How to use it as a shopper

You don’t need to memorize the Hotlist. A few habits do most of the work:

• Buy from sellers you’d trust to follow Canadian rules, and be wary of imported creams that promise dramatic results.
• For products that claim to treat something, look for a DIN or NPN on the label.
• If you know you react to a specific ingredient, read the ingredient list every time. That protects you in a way no national list can.

In short: the Hotlist is Health Canada’s public list of ingredients that are banned from cosmetics or allowed only under set conditions. It changes as the evidence changes, and it helps keep everyday products within safe limits. But it’s a floor, not a seal of approval, and your own label-reading still matters.