When lash artists or brands think about compliance, the first question is usually:

“Is the formula legal?”

That matters — but it is only one part of the picture.

A professional eyelash extension adhesive can contain ingredients that are legally permitted and still be considered non-compliant because of how it is labeled, notified, marketed, distributed, or sold.

That distinction became very clear in Health Canada’s 2023–2024 compliance verification project involving cyanoacrylate-based eyelash extension adhesives.

What Health Canada Reviewed

Health Canada reviewed:

• 54 notified cyanoacrylate-containing eyelash extension adhesives
• 33 additional products sold at retailers
• 87 products in total

The review considered requirements under the Food and Drugs Act, the Cosmetic Regulations, and the conditions outlined in Health Canada’s Cosmetic Ingredient Hotlist.

Importantly, this was not simply a chemistry review.

Health Canada examined things such as:

• required cautionary statements
• professional-use-only conditions
• cosmetic notification requirements
• how products were being sold at retail
• whether product labels and webpages matched regulatory conditions

Compliance Is More Than Formulation

A product may contain a legally permitted cyanoacrylate and still be non-compliant if one of those other pieces is wrong.

What Problems Did Health Canada Identify?

Health Canada reported several types of non-compliance in the project.

Health Canada’s review resulted in actions including stop sales, stop distributions, and commitments to correct non-compliance.

For the notified products alone, Health Canada reported:

• 7 stop sales
• 12 stop distributions
• 14 commitments to address non-compliance

For products identified at retailers, the agency reported:

• 3 stop sales
• 5 stop distributions
• 1 commitment to address non-compliance

What Does “Professional Use Only” Mean?

Health Canada’s Cosmetic Ingredient Hotlist states that cyanoacrylate adhesives intended for eyelash extensions must be sold for professional use only and not for direct sale to consumers.

Health Canada also requires cautionary statements to the effect of:

• For application by trained professionals only
• Ensure the eye is protected and immobilized during application
• Warnings about immediate skin bonding
• Avoid contact with eyes, mouth, and skin

Why Distribution Matters More Than Many Brands Realize

Professional lash products are no longer sold only through traditional professional distributors.

Brands now sell through:

• Shopify
• Amazon
• social media
• online marketplaces
• direct-to-consumer storefronts
• influencer-driven commerce

That means distribution is no longer just a business decision.

For some products, it can become a regulatory decision too.

If a product is restricted to professional use, making it easily available for direct consumer purchase can create a compliance issue even if the formulation itself is otherwise acceptable.

Cosmetic Notification Matters Too

Under Canada’s Cosmetic Regulations, manufacturers and importers must provide required cosmetic notification information to the Minister no later than 10 days after first sale.

Current regulations also restrict continued sale where required notification information has not been provided.

That makes notification part of the launch process — not an optional administrative step after the product is already on the market.

An Important Clarification About the 87 Products

Health Canada specifically explains that inspectors do not select products randomly.

Instead, they select products that are more likely not to meet health and safety requirements.

Because of that, the findings from these 87 products should not be interpreted as meaning that the same proportion of the entire lash adhesive market is non-compliant.

This distinction matters because enforcement data is often shared online without the context of how products were selected.

A targeted compliance project is designed to identify problems.

It is not the same thing as a representative industry survey.

Why This Matters for Lash Artists

Even if you are not a manufacturer or importer, this still matters.

As a professional lash artist, you should know whether the adhesive you are purchasing:

• is intended for professional use
• carries the required warnings
• comes from a transparent supplier
• is appropriately distributed
• appears to meet Canadian regulatory conditions

The product in your hand is part of your professional practice.

Why This Matters for Lash Brands

For brands, the takeaway is even bigger.

Compliance needs to be evaluated as a system.

References

1. Health Canada. Compliance Verification Project 2023–2024: Cosmetic Regulations — Cyanoacrylate Ingredients.
   View Health Canada report
2. Health Canada. Cosmetic Ingredient Hotlist — Cyanoacrylate-Based Adhesives.
   View Cosmetic Ingredient Hotlist
3. Government of Canada. Cosmetic Regulations, Section 30 — Notification.
   View Section 30
4. Government of Canada. Cosmetic Regulations, Section 15.3.
   View Section 15.3