Your candles smell of fig and cedarwood, the wicks are straight, and the jars look right on a shelf. The part that trips up more makers than any wicking problem is the small print. If you sell scented candles in the UK, you are supplying a chemical mixture to consumers, and that brings labelling duties under the Classification, Labelling and Packaging Regulation — retained in UK law as GB CLP. Get it right and it is a one-off job you repeat for each scent. Get it wrong and you will hear from trading standards. Here is what you actually need to show.

Does CLP apply to your candles?

The short answer is yes, if there is fragrance in them. CLP applies to chemical mixtures placed on the market, and a scented candle contains fragrance oil, which is itself a mixture of substances. Some of those substances are classified as hazardous — skin sensitisers and substances harmful to aquatic life are the two you will meet most often. Where the fragrance is present at a level that leaves those substances above the classification thresholds in the finished candle, the candle is treated as a mixture and must be labelled accordingly.

Plain candles with no fragrance, no added colourants and no treated wicks usually fall outside this. Add scent and you are in scope. Northern Ireland follows EU CLP through the Windsor Framework, while Great Britain has its own retained version, so the supplier details and notification duties differ slightly even though most label elements are the same.

What has to appear on the label

A compliant CLP label for a fragranced candle will normally carry the following, depending on how the mixture classifies:

  • Supplier identity — name, address and telephone number of the responsible supplier, so a customer or enforcement officer can reach someone. For GB sales this should be a GB address; for Northern Ireland, an address in the EU or NI.
  • Product identifier — the same product name that appears on the safety data sheet. Keep them identical.
  • Nominal quantity — the net weight of the wax or the fill weight.
  • Hazard pictograms — black symbol, white background, red border. The exclamation mark is the common one for skin sensitisation.
  • Signal word — “Warning” or “Danger”.
  • Hazard statements — for example H317 “May cause an allergic skin reaction” or H412 “Harmful to aquatic life with long lasting effects”.
  • Precautionary statements — the P statements that follow from your classification, such as P102 “Keep out of reach of children”.
  • Supplemental statements — most often EUH208, the allergen sentence covered below.
  • UFI, where the mixture is classified for health or physical hazards and a notification to the poisons service is required.

One detail that catches people out: H412 carries no pictogram at all. The environmental pictogram only applies to the more severe aquatic categories. So a candle can need an H412 statement with no symbol beside it.

Allergens: what actually needs declaring

There is a lot of confusion here, mostly because two different rulebooks use the word “allergen”. The list of 26 fragrance allergens comes from cosmetics law, not from CLP. You are not obliged to print it on a candle label. Many makers do so anyway for transparency, which is fine as long as it does not obscure or contradict the required information.

What CLP asks for is this. If your finished candle contains a substance classified as a skin or respiratory sensitiser above 0.1%, and the candle itself is not classified as a sensitiser, you add the supplemental statement EUH208 naming that substance — for example, “Contains limonene. May produce an allergic reaction.” If the candle as a whole is classified as a skin sensitiser, you use H317 and the exclamation-mark pictogram instead. Your fragrance supplier’s allergen declaration tells you which sensitisers are in the oil; you then have to convert those figures to concentrations in the finished candle.

Working out your classification

You do not need to be a chemist, but you do need to be able to show your working. The process is short:

  1. Request the current safety data sheet, the allergen or sensitiser declaration and, if you export or make claims, the IFRA certificate from your fragrance supplier.
  2. Read section 3 of the safety data sheet, which lists the hazardous components and their concentrations, usually as a range.
  3. Multiply each concentration by your fragrance load to get the figure in the finished candle.
  4. Compare those figures with the classification thresholds for each hazard, and check whether any sensitiser sits above 0.1%.
  5. Build your label wording from the statements that follow. Use the suggested wording on the safety data sheet rather than inventing your own.
  6. File the calculation alongside the version of the safety data sheet you used, with its date.

Why the sums matter

Suppose you pour a candle at an 8% fragrance load and the oil contains up to 5% limonene. That gives you roughly 0.4% limonene in the wax — comfortably above the 0.1% sensitiser threshold, so EUH208 applies and the allergen gets named. Drop the same scent to a 3% load in a tealight and you are at about 0.15%, still above the line. The sums are not decoration; they decide what goes on the label.

Where to get the data

Almost everything comes from your fragrance oil supplier. They must give you a safety data sheet free of charge, and they should also provide an allergen declaration and an IFRA certificate. Ask for a fresh copy whenever you order a new batch, because formulations change and safety data sheets get updated. If a supplier will not send a safety data sheet, that is a serious warning sign — without it you have no defensible way to classify your candle.

Do not simply copy the hazard statements from the fragrance oil’s safety data sheet onto your candle label. The oil’s classification is not the candle’s classification. Once the oil is diluted into wax, the concentrations change, and so does the wording. HSE publishes guidance on CLP labelling and is the place to check current rules, including notification and UFI requirements, which have changed since 2021.

Small labels, gift sets and Northern Ireland

Tealights and small tins do not leave much room. CLP

Photo: Daria-Yakovleva / Pixabay