Soap labels use a different system
A body-cleansing soap sold in the UK or EU is normally a finished cosmetic. That means the label needs cosmetic information such as responsible person details, nominal content, batch code, durability information where relevant, warnings and an ingredients list using INCI names. It is not labelled like a candle or reed diffuser.
This distinction matters when a fragrance supplier sends an allergen declaration. The same PDF may be used to calculate candle CLP supplemental wording and cosmetic ingredient allergens, but the final labels are different. Candle labels may say Contains followed by sensitising substances. Soap labels list required allergens inside the ingredients list.
- Candle: CLP hazard label when hazardous.
- Body soap: cosmetic label with INCI ingredients.
- Cleaning soap: check CLP and detergent rules separately.
Thresholds for rinse-off products
For cosmetic fragrance allergens, rinse-off products such as soap commonly use a 0.01% finished-product threshold for allergens that are required to be declared. Leave-on cosmetics use a lower threshold of 0.001%. These thresholds are different from candle CLP triggers, so do not move numbers between systems without checking.
The calculation still starts with the finished formula. If a soap uses 3% fragrance and that fragrance contains 2% linalool, the finished soap contains 0.06% linalool. That exceeds 0.01%, so linalool would normally be listed if it is one of the declarable cosmetic allergens under the current rules.
The old 26 and the expanded EU list
Many suppliers still talk about the 26 fragrance allergens because that was the familiar cosmetic labelling set for years. EU Regulation 2023/1545 expanded cosmetic fragrance allergen labelling beyond that old set, with staged transition periods. Makers selling cosmetics in the EU need to plan for the expanded list rather than relying on an old 26-allergen spreadsheet forever.
This change is about cosmetics. It does not make candle labels use INCI ingredients, and it does not remove CLP duties for home-fragrance mixtures. If your brand sells both soap and candles, keep a separate allergen workflow for each product category.
INCI names and fragrance names
Cosmetic ingredients should be listed using INCI names. The fragrance mixture itself is usually declared as Parfum or Aroma, and declarable fragrance allergens are added by their required ingredient names when thresholds are exceeded. Do not list the supplier's marketing fragrance name as an ingredient.
For example, a soap scent called Sea Salt and Sage is not an INCI ingredient. The label might include Sodium Olivate, Sodium Cocoate, Aqua, Glycerin, Parfum and then relevant allergen names if required. The exact list depends on the soap formula and fragrance allergen data.
- Use INCI names, not marketing names.
- Calculate against the finished soap formula.
- Place declared allergens in the ingredients list.
Using candle fragrances in soap
Not every fragrance sold for candles is suitable for soap. Check the IFRA certificate for the correct cosmetic category, not only the candle or air-care category. A fragrance that is fine at 10% in a candle may have a much lower limit in soap, or may not be recommended for skin-contact products at all.
You also need cosmetic safety assessment. An IFRA certificate and allergen declaration support the file, but they do not replace the finished cosmetic safety report. Before selling soap, confirm that colorants, botanicals, exfoliants and additives are acceptable for cosmetic use.
A workflow for makers with both ranges
Create one fragrance document folder, then split the outputs by product type. For candles, store CLP labels, SDS and IFRA category checks. For soap, store cosmetic safety assessment, IFRA skin-contact category checks, allergen calculations and INCI label artwork. This prevents accidentally putting candle wording on soap or soap ingredients on a candle.
When a fragrance supplier updates an allergen declaration, review both product ranges. The same formula change can affect a candle CLP Contains line and a soap INCI ingredients list in different ways. Good document control is the difference between a quick update and a messy relabel.
Frequently asked questions
Do handmade soap labels need INCI names?
Yes. Body soap sold as a cosmetic should use cosmetic ingredients listed with INCI names, along with the other required cosmetic label information.
Are fragrance allergens listed on soap?
Yes when they exceed the applicable cosmetic thresholds and are required to be declared. They go in the ingredients list.
Is the 26-allergen list still enough for EU soap?
No for long-term EU compliance. Regulation 2023/1545 expanded the declarable cosmetic fragrance allergens with transition periods.
Can I use a candle fragrance in soap?
Only if it is suitable for the relevant cosmetic category and your safety assessment supports it. Check IFRA category limits and supplier guidance.
Does body soap need a CLP label?
Finished body soap is usually labelled as a cosmetic, not with a finished-product CLP hazard label. Cleaning soap is a separate case.