Selling cosmetics online has unlocked massive growth for brands of every size, from global multinationals to small indie startups that rely on social media to build a following. Canadian consumers increasingly expect to find their favourite serums, fragrances, and personal care staples through marketplaces, brand websites, and even cross-border shops that ship direct to doorsteps. But what some newer or international sellers often miss is that selling online does not reduce your regulatory responsibility — it increases it.
When cosmetics are sold online to Canadian customers, every claim, image, ingredient list, and shipping promise is part of your legal product representation under Canadian law. The same Food and Drugs Act and Cosmetic Regulations that apply to a product on a pharmacy shelf also apply to a product sold through Shopify, Amazon, or Instagram. Health Canada considers your product available for sale the moment you list it with a shopping cart checkout option targeting Canadian buyers.
The Same Rules Apply — But With E-Commerce Traps
At the core, selling cosmetics online means you must first comply with all the standard requirements for physical cosmetics. This means your product must meet the definition of a cosmetic under the Food and Drugs Act: it must not claim to treat or prevent disease, it must not make drug-like promises, and it must be safe for its intended use. If you accidentally drift into health claims — common with “clean beauty” or wellness marketing — you risk your product being reclassified as a drug or natural health product, which demands a completely different approval path.
Before listing your product for Canadian shoppers, you must submit a Cosmetic Notification Form (CNF). This form formally notifies Health Canada that your product is for sale here. Even if you fulfill orders from abroad, a CNF is mandatory if your ads, store, or shipping options target Canadian consumers.
Ingredient restrictions also apply in full force. You must ensure your formula does not contain any substances prohibited under Canada’s Cosmetic Ingredient Hotlist, or that you respect limits for restricted ingredients. If your product contains fragrance allergens above the disclosure thresholds, you must list them on the label — which means the physical label on the unit shipped to Canada must match your CNF and your online product description.
How E-Commerce Makes Labeling and Claims Riskier When Selling Cosmetics Online
A common pitfall for online brands is treating website copy and ad text more loosely than printed packaging. But Canadian enforcement treats online representations the same way it treats the label. If your website claims that a moisturizer “repairs eczema” or that a serum “heals acne,” you are now making therapeutic claims. These push your product into drug territory, which means your Cosmetic Notification Form no longer covers you — you now need a product license and you’re under a stricter set of health product rules.
Another frequent slip-up is inconsistent labeling. Many small brands launch with a beautiful digital shop but use labels sourced from overseas suppliers or dropshippers that do not reflect Canadian bilingual requirements. Under the Consumer Packaging and Labelling Act, labels for cosmetics must be bilingual for all mandatory elements: identity, net quantity, warnings, and ingredient list heading. Ingredient names themselves stay in INCI format and do not change language, but all explanatory text must appear in English and French. Customs and Health Canada both check this. If your imported product lands in Canada missing required bilingual content, it can be stopped, refused entry, or flagged for relabeling.
The Cross-Border Twist: Targeting Canada Triggers the Rules
A major regulatory grey zone for some brands is the idea of “passive” availability. Some companies based abroad believe they can ship products into Canada without filing a CNF or respecting local label law because their site is “international.” But if you offer prices in Canadian dollars, advertise shipping times to Canadian provinces, or use paid ads targeting Canadian customers, Health Canada is likely to consider your offer an active sale in Canada — which means all Canadian compliance rules apply. If your warehouse or fulfillment center is in the US but you serve Canadian customers directly, you are still responsible for meeting Canadian safety, ingredient, labeling, and notification requirements.
Bilingual and Digital: How Your Online Content Becomes Part of the Label
Another subtle compliance point for e-commerce is that your online descriptions and digital images are part of what Health Canada can inspect. When a product is reviewed for compliance, authorities look at the physical product, its shipping container, and its online representations. Claims on the product page must match what the physical label says. If your CNF lists one ingredient order but your online listing says something different, that is a risk. If your online photo shows a version of the product with an out-of-date label that does not reflect a reformulated version, that can also be flagged as misleading. In short, brands should treat online content updates with the same rigor as packaging updates — they are two sides of the same compliance coin.
Shipping and Customs Declarations: Who is Liable When Selling Cosmetics Online?
When you sell online to Canada, your package passes through customs. Inspectors may request your Cosmetic Notification Form or check the declared ingredients and product claims. If you ship directly, you as the brand are responsible. If you sell through a marketplace, the marketplace or fulfillment partner can sometimes share the compliance burden — but the product owner remains liable for the truth and accuracy of what’s inside the box and what is written on it.
A product that includes a banned substance or a misleading claim may be seized, or worse, lead to a public recall if consumers report reactions. For e-commerce brands that rely on trust and repeat purchases, a single enforcement notice can undo years of careful brand-building.
The Responsible Person Requirement Still Stands
E-commerce brands selling to Canada must also name a Responsible Person with a valid Canadian address for every cosmetic product. This contact is who Health Canada communicates with if they have questions or need to review documentation. For Canadian domestic brands, this is usually the company’s head office. For foreign sellers, appointing a local representative is standard practice. Dropshippers and international sellers often forget this piece, but a missing or fake Responsible Person contact on your CNF can invalidate your filing.
Advertising, Influencers, and Social Media
Modern e-commerce lives and dies by digital marketing. Health Canada considers influencer endorsements and social posts by the brand or its agents as part of a product’s representations. If an influencer hired by your brand says a cosmetic “treats rosacea” or “eliminates fungal infections,” that claim is attributed to you. The same goes for hashtags, paid ad text, or videos embedded on your site. This means brands must brief affiliates and content partners carefully — everyone promoting the product must stick to claims that stay within the cosmetic category.
Practical Steps to Stay Compliant When Selling Cosmetics Online
Brands that succeed online in Canada tend to make smart, simple moves upfront: confirm their product really is a cosmetic by Canadian definition, audit every marketing claim for therapeutic drift, prepare a complete and accurate CNF with correct INCI names and concentrations, and file it before listing the product for sale. They double-check that their physical labels comply with bilingual and allergen rules. They make sure every product page and ad matches what’s on the package. They appoint a Responsible Person who can respond to Health Canada quickly if questions arise. And they monitor their supply chain to catch formulation changes that could push an ingredient over a limit or add a new fragrance allergen requiring disclosure.
The E-Commerce Edge: Transparency and Trust
For e-commerce brands, full compliance isn’t just about avoiding fines. It’s about trust. Canadian shoppers are savvy. They read labels. They expect ingredient transparency and accurate claims, especially when they can’t see or touch the product in person before clicking “Buy.” Brands that treat regulatory care as part of the customer experience signal that they care about safety as much as sales.
As more brands compete for Canadian online shoppers, those that handle the basics — correct claims, clear bilingual labeling, honest ingredient disclosure, valid Responsible Person, and a current CNF on file — are the ones who stay out of enforcement trouble and keep repeat customers coming back.
