CLP Labelling for Candles: UK Requirements

What Is CLP?

Classification, Labelling and Packaging. EU regulation adopted into UK law. It requires you to warn customers about hazardous substances in your products.

Do I Need CLP Labels?

If your candle contains fragrance oil: yes, almost certainly.

Unscented candles with no additives: usually no.

The fragrance is what triggers CLP requirements. Most fragrance oils contain sensitising or irritant ingredients that require labelling.

What Must Be On a CLP Label?

1. Product Identifier

What the product is and the fragrance name.

Example: "Soy Candle - French Lavender"

2. Hazard Pictograms

The red diamond symbols. Most candles need:

• GHS07 (exclamation mark) - for irritants
• GHS09 (dead fish/tree) - for environmental hazards

Some fragrances also require GHS02 (flame) for flammability.

3. Signal Word

"Warning" or "Danger" depending on hazard severity.

Most candle fragrances trigger "Warning" (less severe than "Danger").

4. Hazard Statements (H-Codes)

Standard phrases describing the hazard. Examples:

• H317: May cause an allergic skin reaction
• H319: Causes serious eye irritation
• H411: Toxic to aquatic life with long lasting effects

5. Precautionary Statements (P-Codes)

How to handle the product safely. Examples:

• P102: Keep out of reach of children
• P264: Wash hands thoroughly after handling
• P501: Dispose of contents/container in accordance with local regulations

6. Supplemental Information

May include:

• EUH208: Contains [ingredient]. May produce an allergic reaction.
• List of sensitising ingredients above 0.1%

7. Supplier Details

Your company name, address, and contact information.

8. Nominal Quantity

Net weight or volume (e.g., 200g)

9. UFI Code (From 2025)

Unique Formula Identifier. A 16-character code that links your product to poison control databases.

Required for all new products from January 2025. Existing products need updating by 2025.

Where Does the Label Go?

On the container itself (the jar or tin), not just outer packaging.

If you also use a gift box, the CLP info should be visible on the outer box too.

Minimum Label Size

CLP specifies minimum sizes for hazard pictograms based on package size:

• Packages up to 3L: Pictograms at least 10mm x 10mm
• Larger packages: Pictograms at least 16mm x 16mm

The full label should be at least 52mm x 74mm if possible, but smaller labels are permitted for small packages with reduced information.

Where to Get CLP Information

Your fragrance supplier should provide Safety Data Sheets (SDS) for each fragrance oil. The SDS contains:

• Which hazard pictograms are needed
• Which H-codes and P-codes apply
• List of sensitising ingredients

If your supplier doesn't provide SDS, find a different supplier.

Creating CLP Labels

Options:

1. DIY: Use Canva or similar with CLP pictogram images. Check the SDS for each fragrance and include correct codes.
2. Templates: Avery and other label companies offer CLP templates.
3. Professional services: Companies that create compliant labels for you based on your formulations.

Common Mistakes

• Using wrong pictograms for the fragrance
• Missing UFI code (required from 2025)
• Pictograms too small
• Not updating labels when you change fragrance suppliers
• Missing supplier contact details

What Happens If You Don't Comply?

Trading Standards can:

• Issue warnings
• Require product recall
• Issue fines
• Prosecute for serious breaches

Insurance may not cover claims if products weren't properly labelled.

Further Reading

HSE (Health and Safety Executive) guidance on CLP: hse.gov.uk/chemical-classification

Business Companion guide to candles: businesscompanion.info