After six years of consultations and stakeholder engagement, Health Canada is proceeding with updating the Cosmetic Ingredient Hotlist for Alpha-Hydroxy Acids (AHAs). The proposed update aligns with the 2023 consultation proposal, with minor adjustments.

AHAs were initially restricted on the Hotlist in 2003 due to concerns about skin irritation and increased UV radiation risk. A review in 2018 identified additional AHA synonyms and salts, including PHAs, prompting a pause for formal consultation. Multiple consultations occurred in 2020 and 2023, during which stakeholders suggested modifying the AHA entry to reflect the milder nature of PHAs. However, lacking sufficient health and safety data hindered this change. A retrospective analysis of clinical data highlighted skin irritation concerns, particularly with AHA concentrations exceeding 18%. Notably, data on products solely containing PHAs were limited.

Concerning product scope, suggestions to limit AHA entry to specific skincare categories lacked supporting evidence, leading HC to maintain the entry’s broad scope. Furthermore, products not directly applied to skin, such as those for hair and nails, will have separate conditions considering incidental exposure risks. While Health Canada remains open to new evidence, the update reflects a culmination of dialogue and review, aiming to ensure consumer safety regarding AHA-containing products.

The final Hotlist updates are to be published in Spring 2024.

To understand how these updates may affect your business, please reach out to us.