Why the 26-allergen phrase causes confusion
The famous list of 26 fragrance allergens comes from older cosmetic labelling practice. It is familiar because soaps, lotions and perfumes used those names in ingredients lists when thresholds were exceeded. Candles are not finished cosmetics, so the candle label does not work like a cosmetic INCI list.
For candles and wax melts, allergens usually appear through CLP supplemental labelling, often as a Contains line naming sensitising substances that may produce an allergic reaction. The names may overlap with the old cosmetic 26, such as linalool or limonene, but the legal route and threshold logic are different.
- Cosmetics use ingredient-list allergen rules.
- Candles use CLP classification and supplemental hazard labelling.
- Do not assume only 26 fragrance substances matter for CLP.
What a candle allergen report tells you
A fragrance allergen report usually lists substances present in the neat fragrance oil and their percentages. It may be formatted for cosmetics, candles or general use. The useful part for candle makers is the concentration data, but you still need to convert it to the finished candle percentage and apply the correct CLP trigger.
For example, if a fragrance contains 3% limonene and the candle uses 8% fragrance, the finished candle contains 0.24% limonene. That result is not the same as 3%, because the fragrance has been diluted into wax. The finished-product percentage is what matters for the candle label.
How to calculate final allergen percentage
Use this simple formula: fragrance load percentage multiplied by allergen percentage in the fragrance, divided by 100. A candle with 6% fragrance containing 2% linalool has 0.12% linalool in the final product. A wax melt with 10% of the same fragrance has 0.20%. The scent is the same, but the label may not be.
If you combine fragrance oils, calculate each allergen contribution from each oil and add the matching substances together. Limonene from orange oil and limonene from a lavender blend is still limonene in the final product. Blending is one reason supplier ready-made labels may stop applying to your exact recipe.
- 6% fragrance x 2% allergen / 100 = 0.12% in the candle.
- Add the same allergen across multiple fragrances.
- Recalculate when the fragrance load changes.
CLP wording is not a marketing ingredient list
A candle CLP allergen line should follow the required hazard wording from the classification source. It is not the place to list every pleasant-sounding botanical component, and it is not the same as an ingredients list. Over-listing can make labels confusing; under-listing can leave required hazard information out.
Use the substance names from supplier data. Do not rename limonene as citrus essence or linalool as lavender note. The purpose is to identify sensitising substances clearly for people who already know they react to them and for anyone handling a complaint or exposure incident.
How cosmetic allergen changes affect candle makers
EU cosmetic allergen labelling changed under Commission Regulation (EU) 2023/1545, expanding beyond the old 26. That matters if you also make soap, perfume, lotion or other cosmetics. It does not turn candle labels into cosmetic labels, but it does mean the phrase 26 allergens is increasingly outdated even in cosmetics.
For a business that sells both candles and body products, keep two workflows. Use CLP for candles, wax melts, diffuser oils and room sprays where applicable. Use cosmetic rules, INCI names, safety assessment and cosmetic allergen thresholds for finished cosmetics. The same fragrance file can feed both workflows, but the labels are different.
What to ask your supplier
Ask for the fragrance SDS, allergen declaration, IFRA certificate and a finished-product CLP sheet for your product type and use level. If the supplier gives a candle CLP label up to 10% fragrance and you use 8%, confirm that your wax, additives and market match the assumptions. If you use 12%, ask for new data.
Store those documents with your recipe and label artwork. If the supplier reformulates the fragrance, the allergen percentages can change even when the scent name stays the same. A good maker compliance habit is to treat every revised allergen report as a reason to review the affected labels.
Frequently asked questions
Do candles have to list the 26 fragrance allergens?
Not as a cosmetic-style 26-allergen ingredients list. Candles use CLP classification and supplemental labelling for relevant sensitising substances.
What does Contains mean on a candle CLP label?
It usually introduces named sensitising substances that can cause an allergic reaction and need supplemental CLP wording in the finished product.
How do I calculate allergens in a candle?
Multiply fragrance load by the allergen percentage in the fragrance, then divide by 100. Compare the finished percentage with the applicable CLP rule.
Do essential-oil candles still have allergens?
Yes. Essential oils naturally contain substances such as limonene, linalool, citral, geraniol or eugenol, which may trigger labelling.
Do the new EU cosmetic allergen rules apply to candles?
They apply to cosmetics, not to candles as finished home-fragrance products. Candle makers who also sell cosmetics need a separate cosmetic labelling workflow.