The European Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging (CLP) entered into force on 20th January 2009 in all EU Member States, including the UK. It is the European implementation of UN Globally Harmonized System (GHS) of classification and replaces the Dangerous Substances Directive and the Dangerous Preparations Directive. As of June 2015, CLP labeling became mandatory on all consumer and workplace products sold in the EU.
CLP (CLASSIFICATION, LABELLING AND PACKAGING)
What is CLP?
In 2008, the EU authorities were asked to decide if candles and wax melts were mixtures or articles under CLP and the EU REACH regulations. If they were classed as articles, then they would be except from CLP labeling however if they were classed as mixtures, then they must be classified and labeled in accordance with CLP. They were determined to be mixtures under CLP and not articles by a ruling of the European Commission and therefore must be labeled accordingly.
CLP applies to products such as candles, wax melts and reed diffusers containing hazardous chemicals. From 1 June 2015, new products must be labelled in accordance with CLP law and applies to any product of any size containing fragrance or essential oils. There will be a 2 year sell through period allowed for products manufactured before June 2015 however from June 2017 labelling will be mandatory on all products. Ingredients like waxes are non-hazardous however and do not contribute to the classification.
How can we help?
At Whicksnwhacks we provide you with the Safety Data Sheet (SDS) and CLP label template for a 10% fragrance load at point of sale. You will find this information on every individual fragrance oil page with PDF links to the SDS and CLP template documents, example below:
CLP templates are free of charge and provided as a matter of courtesy. You will be able to copy and past the information from the PDF document into your preferred program and edit with your company logo and supplier identification details. The information we provide is just the CLP elements required on your labels so you may also wish to add the relevant safety instructions for your candle or wax melts and incorporate it all into one label.
In the near future we hope to add more label template options for different percentages but in the mean time if you require a label template for a different fragrance load then please feel free to get in contact. It is important that you thoroughly check you are completely happy with the information we have provided prior to purchase as refunds cannot be issued afterwards.
What needs to be included on the label?
For products of 125ml or more your label must be a minimum of 52 x 74mm in size and, if triggered, must contain the following information:
- Product identifier
- Hazard Pictograms
- Signal Word
- EH208 Information
- Hazard (H) Statements
- Precautionary (P) Statements
- Supplier Identification
Product Identifier - This is the name of your product e.g Apple.
Hazard Pictograms - These are the relevant warning images which correspond to each hazard statement present in your product. They must be at least 1cm square in size, diamond shaped and show a black image on a white background with a red frame.
Signal Word - These are words such as 'Warning' or 'Danger' and which one you use, if either, depends on which hazard statements are triggered.
EH208 Information - These are the allergen ingredients which make up your products hazards. The regulations state that no more than four chemicals should be included on the label unless it is necessary to include more due to the nature and severity of the hazard.
Hazard (H) Statements - These are included in order to inform the customer of any hazards present within your product. These along with the relevant pictograms are triggered by particular ingredients when they reach a certain limit.
Precautionary (P) Statements - These correspond to each hazard statement and advise the customer how to avoid or minimise any hazards present in your products.
Supplier Identification - This information must include your business name, registered address and best contact telephone number.
I have been told that products below 125ml do not need to have CLP, is this true?
Sadly this is false. You will hear constantly that CLP is not required for products of 125ml or less however this is not the case. CLP is still required however certain items may be omitted. The exemptions allow the supplier to omit the hazard and/or precautionary statements or the pictograms from the label elements normally required under CLP.
Section 5.3 starting on page 37 of the following document explains this in more detail:
European Chemicals Agency (ECHA) - https://www.echa.europa.eu/documents/10162/13562/clp_labelling_en.pdf
Can I not just use the same label on all of my products?
Unfortunately this is not possible. There is not a 'one size fits all' label and every fragrance oil will need a completely different CLP as each one will detail different information specific to that scent. Each fragrance oil will trigger its very own set of hazard pictograms, signal word, EH208 information, hazard and precautionary statements therefore each label will be different.
My product doesn't trigger any allergens, do I still need to apply a CLP label?
Yes you do. Even if your product doesn't trigger any allergens at your chosen fragrance load you still need to put a CLP label on it. For example, you will see below that our Butterscotch Candies CLP template does not trigger any hazard pictograms, signal word or EH208 information. Despite this CLP still applies in order to provide the customer with the product identifier, hazard statement, precautionary statements and supplier identification details.
Where can I find the hazard pictograms?
The two most commonly used pictograms you will use on your finished products are:
- Health hazard/Hazardous to the ozone layer (Symbol: Exclamation mark)
- Hazardous to the environment (Symbol: Dead tree and fish)
You may find others present on the SDS document for the 100% fragrance oil but usually these drop off depending on the percentage used in your finished product. You can find the full list of hazard pictograms and explanations here:
Health and Safety Executive (HSE) - http://www.hse.gov.uk/chemical-classification/labelling-packaging/hazard-symbols-hazard-pictograms.htm
Where can I include the relevant candle safety information?
The label templates we provide only detail the required CLP elements so you will need to either create one label which encompasses both the CLP and candle safety information or two different labels, one for CLP and one for the candle safety. The most commonly used ones are:
- Never leave a burning candle unattended.
- Burn candle out of reach of children and pets
- Do not burn candles on or near anything that can catch fire.
- Trim wick to about 1cm before lighting.
There are 17 candle safety pictograms in total and you will be able to find all of them along with the corresponding warning statements here:
The British Candlemakers Federation - http://www.britishcandles.org/?pages_id=23
In addition to this, if your finished product does not trigger the 'Health hazard/Hazardous to the ozone layer (Symbol: Exclamation mark)' pictogram as detailed above then you must include the general warning symbol as shown below.
Where can I find some additional information?
Please find below some helpful links to aid you with your research:
European Chemicals Agency (ECHA) - https://echa.europa.eu/regulations/clp/legislation
Health and Safety Executive (HSE) - http://www.hse.gov.uk/chemical-classification/legal/clp-regulation.htm
The information we have provided on this page is based on our interpretation of the regulations and is only meant as a guide. Although we take every care to confirm its accuracy this cannot be guaranteed and it is ultimately your responsibility to ensure you understand the regulations and put them in place accordingly. It may be necessary to contact your local trading standards office to make sure you comply within the correct guidelines. Regulations often change and we cannot guarantee that this page will always be updated to reflect this. We also do not have any control over the content on the sites we have linked to above and in no way endorse their validity.
This information is correct as of 1st January 2017.