How to start a skincare brand in Canada, step by step

To start a skincare brand in Canada, you pick a customer and a hero product, choose private label or custom formulation, prove the formula is stable and well preserved, make sure every ingredient clears Health Canada’s Cosmetic Ingredient Hotlist, then label in English and French and file a Cosmetic Notification Form within 10 days of your first sale. There’s no pre-market approval for cosmetics in Canada, so the work that keeps you out of trouble happens before you sell, in the lab and on the label. Plan on roughly 6 to 12 months for a custom formula and a few months for private label.

Key facts for 2026

• Health Canada requires a Cosmetic Notification Form (CNF) within 10 days after first sale, and it’s free to file.
• Any change to the formula, product name or company details needs an updated CNF within 10 days.
• Since March 5, 2025, the CNF must include a Canadian address for the manufacturer or importer, per Health Canada’s notification guide.
• Product identity, net quantity, warnings and directions go on the label in English and French. Ingredients use INCI names.
• From April 12, 2026, 24 fragrance allergens must be named on labels above 0.001% in leave-on and 0.01% in rinse-off products. New products add a longer list from August 1, 2026, and existing products by August 1, 2028.
• A claim to treat or prevent a condition (acne, scarring, sun protection) makes the product a drug or natural health product, which needs a DIN or NPN.

If you’re still working out the budget, our breakdown of what it actually costs to start a beauty brand covers the money side. This page is the sequence.

Who is your customer, and what’s the one product they’re missing?

Start with a person and a gap, because a skincare line built around “clean, effective products for everyone” has nothing to formulate toward. The brief a chemist needs looks more like this: a 35-year-old in Calgary with dry, reactive skin who’s tired of heavy creams pilling under sunscreen in January. That sentence tells you texture, pH range, which actives to avoid, the climate it has to survive, and what the competition gets wrong.

So pick one or two hero products to launch with. Not seven. Every SKU adds its own stability study, its own challenge test, its own label and its own CNF, which is why a tight launch gets to market faster and cheaper. You can add the toner and the eye cream once the first product proves people come back for it.

Write the brief down. Target skin type, the feeling on skin, the claims you want to make, the price you want to sell at, the packaging you’re picturing, and two or three products you’d want to beat. This one page will save you weeks of back-and-forth later.

Should you choose private label or custom formulation?

This is the biggest decision you’ll make, and it sets your timeline, your minimums and how different your product can actually be. Private label means you buy an existing stock formula from a manufacturer and put your brand on it. Custom formulation means a chemist develops a formula for your brief, and you own it.

Here’s the thing about private label. It’s a fine way to test whether people will buy from you at all, and we’ve written about private label with no minimum orders for founders who want that route. But the same base cream can sit under five other brands’ logos, so your story ends up carrying all the weight. If your brand’s promise depends on a texture, an active or a sensitivity profile nobody else has, you’re looking at custom.

What happens during formulation and stability testing?

Formulation is the chemist turning your brief into lab samples, usually over several rounds. You try sample one, give feedback on feel, scent and finish, and the chemist adjusts. Expect a few rounds before you approve a version. At Atomic Pom Labs, the development fee covers three sample rounds and that full development and production typically run 6 to 12 months.

Once you approve a sample, it goes into stability testing. The point is to find out whether the product will still look, smell and perform the same after months in a hot car or a cold mailbox. Ingredient supplier MakingCosmetics describes the usual approach: storing samples at raised temperatures, most often 37 °C and 45 °C, cycling them through freeze and thaw, putting them under light, and testing in the actual package. A standard accelerated study runs about three months. Our Accelerate Test, for example, is a study that takes roughly 95 to 105 days, with checks on appearance, odour, colour, pH, density and viscosity.

And here’s the part founders miss. Accelerated testing gives you a prediction of shelf life, and a prediction can be wrong. That’s why we recommend the product still has to sit at room temperature, 25 °C, for a year to confirm what the heat test predicted.

Any product that contains water also needs a preservative efficacy test, usually called a challenge test. The lab deliberately adds bacteria, yeast and mould and measures whether your preservative system knocks them back. The common methods are ISO 11930 and USP. This test also informs the period-after-opening symbol on your jar.

For more on where the formula ends and the factory begins, see cosmetic formulation vs manufacturing.

What does Health Canada require before you sell skincare?

Less paperwork than most people expect, and more responsibility. Health Canada doesn’t approve cosmetics before they go on sale. Instead, the Food and Drugs Act says you can’t sell a cosmetic that may cause injury under normal use, and the Cosmetic Regulations set the notification and labelling rules. If something goes wrong, Health Canada can stop sales, issue a public warning, seize product or prosecute. So the burden of proving your product is safe sits with you.

Check every ingredient against the Hotlist. The Cosmetic Ingredient Hotlist has two tables, prohibited and restricted. Restricted ingredients come with concentration limits or required warnings. Health Canada is clear that the list isn’t exhaustive and that there’s no legislated transition period when something new is added, so this check isn’t a one-time thing.

File your CNF within 10 days of first sale. The manufacturer or importer submits it online, and there’s no fee. According to Health Canada’s notification page, it asks for the brand and product name, who’s submitting, manufacturing and import details, the label contact, whether it’s leave-on or rinse-off, where it’s applied, its form, and every ingredient with its concentration. Concentrations can be entered as exact values or in ranges. Change the formula or the name later, and you’ve got 10 days to update the notification. Test-market products need a CNF too.

Label in both official languages. Health Canada’s Industry Guide for the labelling of cosmetics spells out what goes where. The product identity and net quantity go on the principal display panel in English and French. Net quantity is metric, and the guide wants the number in bold with a space before the unit, like 50 mL. Warnings and directions for safe use need both languages. Your dealer name and address can be in either language, and the consumer contact has to be able to answer in both. Products sold in Quebec may face extra French-language rules on top of this.

Write the ingredient list in INCI. Ingredients go in descending order by weight, and anything at 1% or less can follow in any order. “Parfum” works on the list, “fragrance” alone doesn’t. Small containers can carry the list on a tag, or on a website if the label has a bilingual statement pointing there.

Name the fragrance allergens. This is the 2026 change. From April 12, 2026, 24 allergens have to be named outside “parfum” when they’re above 0.001% in a leave-on product or 0.01% in a rinse-off. New products also have to disclose a second, longer list from August 1, 2026, and existing products have until August 1, 2028. If you’re using an essential oil blend, ask your chemist for the allergen breakdown before the label goes to print.

Keep proof for “not tested on animals.” Canada’s cosmetic animal testing ban took effect December 22, 2023, and Health Canada says companies need to keep evidence for any cruelty-free claim, in words or images.

When does a skincare product become a drug or natural health product?

The moment the claim says it treats, prevents or changes how the body works. Health Canada’s guidance on the cosmetic-drug interface classifies products mainly by what you say they do, looking at the net impression of the label, packaging and ads together. Cosmetics can clean, moisturize, improve the look of skin and have small, local, temporary effects. Therapeutic claims are only allowed on drugs and natural health products.

Health Canada’s own examples make the line easy to see. A cleanser for oily skin with no therapeutic claim is a cosmetic. An acne gel that claims to kill acne bacteria, with benzoyl peroxide, is a drug with a Drug Identification Number. A herbal cream that claims to help scars heal faster is a natural health product. And every sunscreen sold in Canada needs a DIN or a Natural Product Number, so the minute you put SPF on a moisturizer, you’ve left the cosmetic rules behind.

So watch your copy, and watch your Instagram captions too. “Helps skin look smoother” is cosmetic. “Repairs damaged skin barrier in eczema” isn’t. Your marketing counts as a representation, same as your label.

Not sure your formula, claims or label are ready? Our free readiness evaluation flags the gaps before you print anything.

How do you choose a manufacturer and packaging?

Pick the manufacturer based on the product you developed, because not every facility can make every format. A plant set up for oils and balms may not run hot-process emulsions well, and a large contract manufacturer might want minimums that don’t fit a first launch. Ask each one for their minimum order, whether they’ll run a pilot batch, which test reports they’ll share, and how they handle batch records. The Food and Drugs Act requires sanitary conditions for manufacturing, packing and storage, so ask how they meet it.

Packaging is a lab decision as much as a design one. The formula and the container have to be tested together, because some actives react with certain plastics, airless pumps behave differently from jars, and clear bottles let light in. Lock packaging in before your stability study starts, or you’ll be running it twice. Our cosmetic packaging guide walks through materials and suppliers.

What business registration do you need?

The usual small-business setup, with one tax number to watch. You’ll register a sole proprietorship, partnership or corporation, either provincially or federally, and the Government of Canada’s registration page explains which route fits. You’ll also want a business number from the CRA. For GST/HST, the CRA’s small supplier rule means you have to register once your taxable sales pass $30,000 over four consecutive calendar quarters, though you can choose to register voluntarily before you hit that number.

Two things founders tend to leave late. Product liability insurance, which many retailers and markets ask for before they’ll stock you, and a trademark search on your brand name before you pay for a logo.

Where should you launch?

Most new skincare brands launch direct-to-consumer on their own site first, because they keep the margin and get customer data. Marketplaces like Amazon add reach but take a cut and give you less control over the brand. Retail and spas come later, usually after you can show sell-through, and bigger retailers will ask for your stability, challenge test and safety documentation. So keep those reports organized from day one. They’re part of what you’re selling.

A realistic timeline for a custom skincare launch

These are typical ranges from published sources and our experience. Your project can move faster or slower depending on how fast you give feedback and how complex the formula is.

What we see in the lab

The most common mistake we see is founders treating stability testing as a box to tick at the end. They approve a sample, order 2,000 units of custom-printed bottles, and then the stability study shows the emulsion separating at 45 °C or the vitamin C going brown in the clear packaging. Now they’re reformulating and reprinting. Test in the final container, and don’t place the big packaging order until the first stability checkpoints come back clean.

The second one is claims drift. The formula’s built as a cosmetic, then marketing writes “calms eczema flare-ups” on the website, and suddenly the product is making a drug claim with no DIN. We read the copy the same way we read the formula, because to Health Canada they’re the same product.

And the third is fragrance. A founder falls in love with a natural essential oil blend, and nobody checks it against the allergen lists until the label proof stage. With the 2026 rules, that blend can add four or five names to the ingredient list. Sometimes that’s fine. Sometimes it changes the whole “gentle” positioning, and it’s much cheaper to know that in month two than in month eight.

Your skincare launch checklist

• [ ] One-page brief: customer, skin concern, texture, claims, target retail price
• [ ] One or two hero products chosen, not a full line
• [ ] Private label or custom decided, with formula ownership confirmed in writing
• [ ] Every ingredient checked against the Health Canada Cosmetic Ingredient Hotlist
• [ ] Final packaging chosen before stability testing begins
• [ ] Accelerated stability study done in the real container
• [ ] Challenge test passed (ISO 11930 or USP <51>) for any water-based product
• [ ] Claims reviewed so nothing treats, prevents or heals
• [ ] Label: bilingual identity and net quantity, INCI list, bilingual warnings and directions, dealer name and address, bilingual contact
• [ ] Fragrance allergens named above the 0.001% / 0.01% thresholds
• [ ] Proof kept for any “not tested on animals” claim
• [ ] Pilot batch run and approved
• [ ] Business registered, business number in hand, GST/HST plan set
• [ ] Product liability insurance in place
• [ ] CNF filed within 10 days of first sale, with a Canadian address for the manufacturer or importer

Ready to build something nobody else is selling?

Atomic Pom Labs is run by two scientists, Diego Lapetina (PharmD, MSc, PhD) and lead formulator Annie Graham, with more than 20 years of combined lab experience. We take skincare brands from brief to shelf in Canada, which covers custom formulation, stability, regulatory and labelling, manufacturing setup and launch. If you want a formula that’s yours and a launch that doesn’t stall at the label, book a call with us. Or, if you’re earlier than that, subscribe to The Dispatch, our daily beauty-industry newsletter, and we’ll keep you posted on rule changes like the 2026 allergen dates. Want the bigger picture on development here? Read our guide to cosmetic development in Canada.