Disclaimer: The information in this article presents our understanding and views and is not legal advice. If you need more details on any legislation or legal advice about what action to take when labelling your products, please contact an adviser or solicitor.
What needs to be on a CLP label?
A CLP label must contain the following information, specific to the product, which can be found in Section 1.1 and 2.2 of the product SDS (please note, the product SDS is different from the fragrance oil SDS).
a). Product Identifiers; found in Section 1.1 of the SDS, this is simply the name of your product and the components contributing the most to the overall hazard of your product. You can name your product whatever you’d like, it does not have to be the same as our fragrance name, however, you should change the SDS to reflect this change. The components listed beside the Product Identifier should be kept separate from the Supplemental Information.
b). Signal Word; If applicable, this will be found in Section 2.2 of the SDS, as will the remainder of the information below. CLP has two signal words to indicate the severity of the hazards of the product - Warning and Danger. Most products chandlers will make will either have no signal word, or Warning.
c). Hazard Pictograms; There are nine hazard pictograms within CLP, although most makers will only ever be concerned with two – The exclamation mark pictogram and the environmental hazard pictogram. These should always be displayed as a black symbol on a white background, set within a red diamond and should be an absolute minimum of 1cm in size.
d). Hazard Statements; Your CLP label must have the relevant hazard statements displayed and should be written as they appear on the SDS.
e). Precautionary Statements; These are chosen as your discretion and are generally limited to 6 precautionary statements per product, unless more are necessary to convey the hazards of the product. So simply put, you should choose the precautionary statements that are relevant to your product. For example, the precautionary statement ‘Contaminated work clothing should not be allowed out of the workplace’ is not relevant to a candle or diffuser. The precautionary statement ‘Dispose of contents/container to approved disposal site, in accordance with local regulations’, is mandatory for products being sold to the general public where the product has been classified as an environmental hazard or is subject to legislation on hazardous waste. Others may be highly recommended for use with certain hazard statements, but ultimately, the decision is yours. We hide the precautionary statements we don’t deem relevant on the product SDS’s we provide.
f). Supplemental Information; For candles and diffusers, the supplemental information is the ‘Contains…’ section on the label. These are all of respiratory/skin sensitisers present in the product above a general or specific concentration limit. ‘May produce an allergic reaction’ is always stated at the end of this list, but need not be used if the product is already classified as a skin sensitiser (i.e. the hazard statement ‘May cause an allergic skin reaction’ appears), to avoid duplicate information.
g). Name, address and telephone number of the supplier; the contact details of the supplier/distributor should be made available on the CLP label. The legislation states that one or several suppliers contact details can be placed on the label in case of the same product being manufactured by one supplier and distributed by another, but it does not specify that several are required or which would take precedence. It does specify, however, that if a supplier changes the packaging of a product then they are responsibly for re-packaging and re-labelling and should add their contact details to the product. This means that in the case of contract manufacturing/white label products you are fine to use the contact details of the brand you are making for.
h). The weight (unless stated elsewhere on the product); the net weight of your product (weight of the wax and fragrance oil) should be stated on your CLP label, unless stated elsewhere on the product/packaging.
i). UFI (applicable for those following EU CLP); a recent amendment to EU CLP, a UFI (Unique Formula Identifier) is a 16 digit alphanumeric code that links the product placed on the market with product information that has to be submitted to the relevant Poison Centre of the country you are selling in. The UFI is mandatory for products that are classified as a health or physical hazard, but voluntary for those classified as an environmental hazard only. It must be prefaced by the acronym ‘UFI:’. We will go into more detail regarding UFI’s and Poison Centre Notifications further on in this guide.