What CLP covers
CLP means classification, labelling and packaging. It is the EU system behind red-diamond GHS pictograms, signal words, H statements, P statements and supplemental hazard wording. For makers, it commonly applies to hazardous mixtures such as scented candles, wax melts, reed diffusers, room sprays and fragrance oils placed on the EU or EEA market.
Finished cosmetics are a key boundary. CLP Article 1(5)(c) excludes cosmetic products in their finished state intended for the final user when they are covered by Regulation (EC) No 1223/2009. A handmade soap, lotion or balm normally needs cosmetic compliance, including safety assessment, PIF, CPNP notification, INCI ingredients and cosmetic allergen labelling, not a CLP red-diamond finished-product label.
- Use CLP for hazardous scented mixtures such as candles and diffusers.
- Use cosmetic rules for finished soaps, creams, lotions and balms.
- Natural, handmade and essential-oil products are not automatically exempt.
Required CLP label elements
CLP Article 17 lists the main label elements: product identifier, supplier name, address and telephone number, nominal quantity for public sale unless shown elsewhere, hazard pictograms, signal word, hazard statements, precautionary statements and supplemental information. Articles 18 to 22 deal with the product identifier, pictograms, signal words, hazard statements and precautionary statements.
Article 25 covers supplemental information. Annex III gives standard hazard wording, Annex IV gives precautionary wording and Annex V defines the pictograms. Use the official phrases, not homemade wording, and provide the required language for each Member State where the product is sold.
- Product name or identifier that matches your records.
- Supplier identity and phone number.
- Correct pictograms, signal word, H statements, P statements and supplemental text.
Use supplier data carefully
Start with the fragrance supplier's SDS, allergen statement and any finished-product CLP sheet. The SDS for the neat fragrance oil is useful, but it may not be the classification of your finished candle or diffuser. Dilution, solvent choice, fragrance load and combined oils can change the final mixture classification.
Under CLP Article 4 and Annex I, the mixture placed on the market must be classified before sale. If your recipe differs from the supplier's tested or calculated use level, ask for matching CLP data or have the mixture classified. A label generator can assemble elements; it cannot fix unreliable source data.
- Keep SDS, allergen and CLP calculation records with each batch.
- Check that the fragrance percentage and base match your recipe.
- Do not copy the neat oil label onto a diluted product without checking.
Fragrance allergens and thresholds
For candles and diffusers, the familiar Contains line is normally CLP supplemental labelling for sensitising substances, often shown as EUH208-style wording: Contains [substance name]. May produce an allergic reaction. Many candle CLP sheets use a practical 0.1% final-product threshold for relevant skin sensitisers, but specific concentration limits and supplier classification data can change the answer.
Cosmetic allergen declarations are different. Regulation (EC) No 1223/2009 Article 19 and Annex III require fragrance allergens in the ingredients list above 0.001% in leave-on cosmetics and above 0.01% in rinse-off cosmetics. Commission Regulation (EU) 2023/1545 expanded the old 26-allergen list, with transition dates of 31 July 2026 for placing non-compliant products on the market and 31 July 2028 for making them available.
- Final allergen percentage = fragrance load percentage x allergen percentage in fragrance / 100.
- 8% fragrance x 2% linalool / 100 = 0.16% linalool in the candle.
- Compare the result with the threshold for the correct product type.
Worked example: lavender candle
A 200 g lavender candle uses 8% fragrance oil. The supplier's candle CLP sheet for use up to 10% in wax says the finished mixture is Skin Sens. 1 and Aquatic Chronic 2, with GHS07, GHS09, the signal word Warning, H317 May cause an allergic skin reaction and H411 Toxic to aquatic life with long lasting effects. The label should use that classification, not a softer marketing version.
The allergen statement lists 2% linalool, 1.5% limonene and 0.4% coumarin in the fragrance. In the candle, those become 0.16%, 0.12% and 0.032%. Against a 0.1% candle threshold, linalool and limonene are declared, while coumarin is not. The label then needs the product identifier, net weight, supplier details, pictograms, Warning, the H and P statements and supplemental wording naming linalool and limonene.
Common mistakes
Do not treat an IFRA certificate, SDS and CLP label as the same document. IFRA addresses fragrance safe-use limits; SDS and CLP data address chemical hazards; cosmetics files address finished cosmetic safety and ingredient labelling. Another mistake is deleting environmental hazards such as H411 because customers are more focused on skin allergy warnings.
Check UFI and poison centre duties before printing. CLP Article 45 and Annex VIII may require notification and a UFI for mixtures classified for health or physical hazards; environmental-only mixtures are not generally in that Annex VIII scope. Also update labels when supplier data, your recipe or classification changes; CLP Article 30 covers label updates.
- Using old orange symbols instead of CLP red diamonds.
- Applying cosmetic thresholds to candles, or candle thresholds to cosmetics.
- Forgetting required languages when selling into another EU country.
- Printing labels too small for pictograms and hazard text to be legible.
Frequently asked questions
Do candles need CLP labels in the EU?
Yes, if the finished candle is classified as hazardous under Regulation (EC) No 1272/2008. Fragrance ingredients often trigger skin sensitisation or environmental labelling.
Do wax melts and reed diffusers need CLP labels?
Often yes. They are scented mixtures, not cosmetics, so use final-mixture CLP data for the actual base and fragrance load.
Does handmade soap need a CLP label?
A finished soap sold as a cosmetic is normally regulated under Regulation (EC) No 1223/2009 because of CLP Article 1(5)(c). It still needs cosmetic safety and allergen labelling.
What is EUH208 on a candle label?
EUH208 is supplemental CLP wording for mixtures containing certain sensitising substances. Candle labels often use it to name allergens such as linalool or limonene.
How do I calculate fragrance allergens for CLP?
Multiply fragrance load by the allergen percentage in the fragrance, then divide by 100. For example, 6% fragrance containing 3% limonene gives 0.18% in the product.
Do I need a UFI code for candles?
You may need one if the candle mixture is classified for a health or physical hazard and is placed on the EU market. Check CLP Article 45 and Annex VIII.
Can I make a CLP label from the supplier SDS?
Use the SDS as source information, but make sure the label matches your final product. If the SDS only covers neat fragrance oil, request final-mixture CLP data.