CLP legislation was introduced within the EU (as the EU implementation of GHS) in order to ensure hazardous chemicals are Classified, Labelled and Packaged in a consistent way. CLP legislation does not cover cosmetic products, as these are provided for by existing legislation; however, other non-cosmetic fragranced products are included, quite often as ‘mixtures’ (the CLP term). Mixtures include things such as washing up liquid, dishwasher tablets, household cleaners, air fresheners, candles and reed diffusers. CLP came into force on the 1stof June 2015 for all mixtures entering the market. Since Brexit, the EU CLP Regulation has been retained in GB law however, any future amendments are independent of each other. Notably, the most recent amendment to EU CLP regarding the implementation of UFI’s on all mixtures classified as a physical or health hazard was not adopted by GB CLP so is not required in Great Britain but is required in Northern Ireland and EU.

Required CLP Information

To be CLP compliant, labels must include the following information:

Supplier Identification: Full address and phone number.

Product Identifier: Name of the product.

EH208 Information: Information on sensitisers.

Hazard Information: Precise details of the hazards.

Precautionary Information: Safety precautions to be taken.

Hazard Symbol: Appropriate symbols to indicate the hazards.

Signal Word: Either "Warning" or "Danger" depending on the severity of the hazard.

Net Weight of Product: The weight of the product​​.

UFI Number: A Unique Formula Identifier (UFI) is required on CLP labels in the EU and Northern Ireland for products classified as health or physical hazards. This is not required in Great Britain​​.

SDS (Safety Data Sheets): These documents are essential for ensuring the safe supply, handling, and use of chemicals. They must be provided by suppliers and contain the necessary information to complete a risk assessment​​.
These sheets are where you can find all of the information needed for the CLP label.
Candle Shack has SDS available for all of its fragrances and provides SDS for products at certain percentage fragrance content too. These can be found on the fragrance webpages.
Candle Shack also has a CLP Design Tool to assist you in creating compliant labels.

Our CLP templates are based on fragrance content, which is defined as the percentage of fragrance oil relative to the total mass of the candle formula (wax and fragrance). If you were to apply our 10% CLP label to a 30cl candle (~220g net weight) it would be made up of 198g of wax and 22g of fragrance. If you are using the fragrance load method, which is defined as the percentage of fragrance oil relative to the mass of the wax only, a fragrance load of 10% would be 200g of wax and 20g of fragrance which amounts to roughly 9% fragrance content, meaning you should apply a 9% CLP label to this product.

The ‘Contains section of the CLP label is triggered if one or more respiratory or skin sensitisers are present in the product above a generic or specific concentration threshold. For Cat 1A sensitisers, >0.01% and <0.1% will trigger the ‘Contains’ section and for Cat 1/1B, >0.1% and <1%. So depending on the concentration of fragrance oil you put into your candles, some of the required warnings will change depending on if the chemicals they contain breach certain thresholds.

It has been thought that a CLP label could cover you ‘up to’ the stated dosage, likely stemming from the fact that it’s ok to produce a possibly overestimated CLP label when working from a ‘banded’ SDS as you have to put in the upper concentration of the hazardous components. The CLP regulation states that it’s ok to classify a diluted product with a more concentrated version if the mixture has been tested. Typically within the candle industry, CLP information for mixtures is calculated using data available for the components within the mixture rather than testing the mixture itself, so I would not assume that it’s ok to use a CLP label to cover ‘up to’ a certain amount. We’d recommend using the correct CLP information for your chosen fragrance content. For those that do choose a load outside of the 8% and 10% templates we provide, contact our customer services via email Support@candle-shack.co.uk and we can help you with sourcing suitable CLP information for your specific concentrations.

If you cannot fit a full CLP label on your candle due to its size or shape, there are specific omissions and alternatives that are permitted under the regulations.
Label Size and Content:

Products over 125g require a full CLP compliant label.

For products where it is impossible to fully label them, such as those not exceeding 125g, you can omit certain details on the product itself as long as the full CLP information is supplied on the outer packaging .

Alternative Labeling Methods:

If your product is too small or has an unusual shape that makes it impossible to fit a full label, you can use alternative methods such as a tie-on tag, fold-out sheet, or placing the information on the outer packaging .

Minimum size for CLP labels should be between 54-71mm, and they must be visible on all packaging at the point of sale .

Required Information:

The essential elements that must be included on the label or alternative method are:

Supplier identification (full address and phone number).

Product identifier.

Hazard information (including symbols, signal words, and precautionary statements).

Net weight of the product (this can be omitted from the label if it is stated elsewhere on the product or packaging) .

By adhering to these guidelines, you ensure that your candles are both compliant with CLP regulations and safe for consumers. For any further assistance or clarification, please contact our customer support team at support@candle-shack.co.uk.

Wax is, usually, not classified under CLP – meaning it carries no hazards/precautionary statements.

However, the fragrance does come under CLP classification and a wax melt with 10% fragrance will have the same precautionary statements and hazards applicable to it as a candle with the same 10% fragrance content.
The only difference is, candles require general safety standard pictograms due to them having an open flame. Wax melts do not require these pictograms and they are not part of CLP.
Candle Shacks CLP design tool can be used for both candles and wax melts by selecting or de selecting these pictograms.

You are required to place your contact details on the CLP label; however, it is not specified whether this needs to be the address where the goods are manufactured or sold etc. The purpose of these details being on the label are so you are contactable, so in our eyes, this can be anywhere that you can be reached i.e. home address, shop, warehouse, PO Box, along with a telephone number.
An email address is not sufficient, a contact phone number is needed.

Article 31(1) of CLP legislation states… “As a general rule, CLP requires labels to be firmly affixed to one or more surfaces of the packaging immediately containing the substance or mixture and that they shall be readable horizontally when the package is set down normally”.

This means on the side of the candle or packaging. Most candle makers choose to place their labels on the base of the packaging or vessel, in keeping with the spirit of the legislation rather than the wording.
The key point is that your CLP label should be visible at the point of sale, so if you supply your candles in an outer box, your CLP label should be on that. It is also permissible to have your CLP on a tag provided that it is visible at the point of sale.
While it has been clarified by ECHA that open glass vessels do not constitute packaging under CLP regulations, we would suggest that since packaging is easily discarded, an additional label be affixed to your product.

A UFI (Unique Formula Identifier) is a 16-digit alphanumeric code that is now a requirement on CLP labels as part of a recent amendment to EU CLP.

UFI codes are only required if you are selling in the EU and Northern Ireland. They are not required in GB

To generate and submit a UFI, you need to gather all the relevant information about your product. Here’s a step-by-step guide on how to find and organize this information:

1. Product Composition:

• Chemical Composition: Collect detailed information about all the substances in your product, including their concentrations. This information is typically found on the safety data sheets (SDS) provided by your suppliers.
• Product Formulation: Document the exact formulation of your product. This should include all ingredients and their proportions.

2. Safety Data Sheets (SDS):

• Ensure you have the latest version of the SDS for each component of your product. The SDS provides critical information about the chemical properties, hazards, handling, storage, and emergency measures.

3. Company Information:

• Company Key: Obtain your unique company key from the ECHA submission portal.
• Company Details: Ensure your company details, such as name, address, and contact information, are up-to-date.

4. Product Identification:

• Trade Name: The commercial name of your product.
• Intended Use: Specify the intended use of the product (e.g., candle making, household cleaner).

5. Labeling Information:

• Prepare a draft of your product label that includes the UFI. The label must also comply with CLP Regulation (Classification, Labelling and Packaging) requirements, showing hazard pictograms, signal words, and precautionary statements if applicable.

6. Generate the UFI:

• Use the UFI Generator Tool provided by ECHA. Enter your company key and the specific formulation number of your product. The tool will generate a unique 16-character UFI code.

7. Notify Poison Centres:

• Preparation: Gather all the required information: UFI, product identifiers, chemical composition, and classification.
• Submit Information: Submit this information to the relevant national Poison Centres through the ECHA Submission Portal. This step ensures that in case of an emergency, the correct product information is available to healthcare professionals.

8. Documentation and Record-Keeping:

• Maintain records of all information submitted to ECHA and Poison Centres. This includes the UFI, product formulation details, and submission confirmation receipts.

Resources:

• ECHA Website: ECHA UFI Generator
• CLP Regulation Guidelines: ECHA CLP
• Safety Data Sheets (SDS): Provided by suppliers, containing chemical properties and hazards.

For any assistance or clarification, you can contact Candle Shack customer service at support@candle-shack.co.uk or consult the ECHA website directly.

While not part of CLP regulations, candle makers tend to place additional information on their safety labels such as.
Batch Number: This helps identify manufacturing information if the product is faulty​​.

Product Safety Label Pictograms: According to EN15494 legislation, certain pictograms are mandatory on the product labels. These pictograms indicate the safety information relevant to the product​​.