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.
Where do I put my CLP Label?
Article 31(1) of CLP 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 that your CLP label should be placed on the side or back of your product packaging, so that it is easily read when sat down normally.
It has been a point of contention in the candle world whether candle containers would be classed as packaging and require a CLP label directly on the side of the glass, with aesthetic and fire safety issues being raised. Most makers place their CLP label on the base of their jars instead, in keeping with the spirit of the law rather than following to the letter.
ECHA did eventually clarify that open containers of glass are not considered packaging in this context and therefore do not require a CLP label; however, the candle should be supplied in packaging that does comply with CLP. We still think it’s a good idea to place a CLP label on the base of your candle, as generally packaging will get thrown out.