Candle Label Requirements – EU Edition
The rules and regulations in the EU and UK for candle makers are complicated and overwhelming, which isn’t surprising given the web of laws and regulators involved.
And although it isn’t sexy or fun, you should know the rules if you’re planning on making and selling candles in Great Britain or the European Union.
In this guide, you’ll learn:
- What parts of the law you should care about as a candle maker
- How Brexit impacts candle making legislation
- How to design a compliant candle label in the UK and EU
As with all things about the law, do not consider this legal advice. Instead, treat this as a starting point for your own journey as a candle maker.
Let’s dive in!
Candle making laws in the EU and UK
The Purple Book – GHS
Before 2002, many countries approached chemical safety differently, adding confusion to suppliers and manufacturers around the world. For example, certain ingredients weren’t allowed in some countries even if neighboring countries didn’t care.
You might have to label certain supplies in one place, but you could get away without it in others.
At the end of the day, the burden fell on consumers to “guess” whether something was safe or not, often with limited or no information about the composition.
At the 2002 World Summit on Sustainable Development in Johannesburg, South Africa, leaders unveiled a new system to help different countries and governments talk about chemicals the same way: the Globally Harmonized System of Classification and Labelling of Chemicals, which most people refer to by the acronym, GHS.
GHS is a system, not the law.
A system suggested to countries for them to build legislation and laws around. Think of GHS like a set of principles for creating a law.
The GHS includes principles and suggestions around:
- Chemical classifications based on their hazards
- How companies communicate hazard levels to their customers
- A lot of other items
Published versions come with a purple binding, leading to the nickname, “The Purple Book”. In 2019 the eight edition came out, totaling 570 pages.
Over 85 countries have adopted the GHS into national and regional legislation. For example, in the United States the GHS guides certain aspects of OSHA and the U.S. Consumer Product Safety Commission.
But what about the European Union and the United Kingdom?
Classification, Labelling, and Packaging – EU CLP
Six years after GHS came out, the EU adopted legislation known as the CLP.
“CLP” stands for Classification, Labelling, and Packaging, and essentially controls how and what you have to communicate about your products.
The main impact of CLP for candle makers is label design.
Unfortunately, CLP-compliant label design isn’t as straightforward as it is in the United States.
In the United States, you don’t need to disclose much about what’s inside. For better or worse, you only have to identify a few things: what kind of product it is, where it was made, and who made it.
The EU also has testing guidelines, which are industry standards, but we’ll cover those later
For now, all you have to know is that your labels have to legally comply with the requirements laid out in the CLP.
Brexit’s impact on candle making
Honestly, the UK’s exit from the European Union didn’t impact too many aspects of candle making. That isn’t to say there aren’t zero, but it’s not drastically different (as of mid-2021).
The UK took CLP (and a few other laws) with it, and creatively renamed them after making a few changes, but not every providence in the United Kingdom complies with the GB CLP:
| European Union | EU CLP |
| United Kingdom | GB CLP |
| Northern Ireland | EU CLP |
If you find yourself doing business in all areas, you’ll have to comply with both EU CLP and GB CLP. At the time of this writing, EU CLP is more strict, meaning you’re “probably” okay if you only look at EU CLP rules.
If you’re in the fragrance game, then you’ll also know that REACH was split into an EU REACH and a GB REACH, but we’re only talking about candle makers for now.
How to make a CLP-compliant label
For the record, if you are selling candles that contain fragrance oil to a consumer in the EU or UK you need a CLP-compliant label on your candle.
There are only two exceptions (most of the time):
- The fragrance oil doesn’t have a single hazardous substance in it… but that’s incredibly rare (which is something your fragrance oil supplier or manufacturer has to worry about)
- You’re using a fragrance load smaller than 0.1% (most use between 6% and 10%)
According to the CLP (Article 31), your label needs to be visible when the product is at rest in a normal position.
Is this followed by all resellers of candles?
Likely not, but that doesn’t necessarily exclude this requirement.
Make sure you write the label in the language where the candle will be sold. Usually that means English.
A CLP-compliant label has the following items (click to jump to that section):
- Supplier identification (the candle maker)
- Weight or mass of the candle
- Product name or identifier
- Hazard pictograms
- Signal words
- Hazard statements
- Precautionary statements
- Relevant supplementary information
- Unique formula identifier (UFI)
And everything starts with obtaining the Safety Data Sheet from your fragrance oil supplier.
1. Download the correct SDS from the supplier (or ask for it)
Before covering each in a bit more detail, it is best for you to download or request the Safety Data Sheet (also called the SDS) for the:
- Specific fragrance oil
- Fragrance concentration
- Intended use (candles, diffusers, wax melts)
Your candle supply company is obligated to provide this to you if you can’t find it.
For example, if you are making an 8% fragrance load candle using Candle Shack’s Paradise Beach fragrance oil, you would want to request the 8% Paradise Beach candle Safety Data Sheet.
Why?
The fragrance maker’s SDS includes almost all the relevant information you’ll need for creating your CLP-compliant label.
Let’s dive into the specifics.
2. Supplier identification (the candle maker)
For smaller candle makers, this section is a bit unnerving but CLP requires you to include the candle maker’s:
- Name (business name)
- Address (where the candle is made)
- Phone number (how the candle maker can be reached)
…and there doesn’t seem to be any substitute for that information.
3. Candle weight or mass
Your label must include the NOMINAL quantity of the candle. This means the weight of wax inside the container, not the entire candle itself, listed in grams.
For example, if your candle components weighed like the following:
| Jar | 100 grams |
| Wax inside the jar | 186 grams |
| Lid | 20 grams |
You would list 186 grams on your label.
This means you don’t take the finished candle and set it on a scale – you have to know how much you’re pouring into the jar.
You can approximate this weight, especially if you’re pouring in batches.
4. Product name or identifier
Article 18 specifies you need to include two items:
- Name of the fragrance oil as it appears in the Safety Data Sheet provided by the supplier
- All substances in the mixture of the following nature, which you can find in section 11 of a properly prepared Safety Data Sheet:
- Acute toxicity
- Skin corrosion
- Serious eye damage
- Germ cell mutagenicity
- Carcinogenicity
- Reproductive toxicity
- Respiratory or skin sensitization
- Specific target organ toxicity (STOT)
- Aspiration hazard
If the substances list is large, you only need to show 4 names, unless you feel compelled to share more, so that’s nice.
5. Hazard pictograms
Pictograms, which are the boxed picture visualizing the hazards, come straight from the Safety Data Sheet for the fragrance oil.
Look at section 2.2 of the SDS to find out which pictograms you need to include.
Article 19 refers to a few rules for pictogram design:
| Shape | Square or diamond |
| Colors | Black symbol, White background, Visible red frame |
| Size | At least 1/15th of the total label area and a minimum of 1cm2 |
| Minimum dimensions | 10mm x 10mm (16mm x 16mm if possible) |
You can download the pictograms in a TIFF format and convert them to a PNG if you don’t have a program that works well with TIFF files.
6. Signal word
Candles almost always warrant the signal word WARNING.
You’ll find the right word on the Safety Data Sheet in section 2.2. The CLP specifies that if the signal word “DANGER” is used, don’t use the word “WARNING” anywhere.
All you need to do is include it on the label somewhere.
7. Hazard statements
Section 2.2 of the SDS calls out every Hazard Statement required for inclusion in your label.
Hazard statements are mapped directly to the classified hazards in Annex I of the CLP.
8. Precautionary statements
Section 2.2 of the SDS also calls out every precautionary statements required for inclusion in your label.
Precautionary statements are available for copy/pasting onto your label design from the CLP.
9. Relevant supplementary information
Call out any additional physical or health properties from the fragrance oil that need to be included using section 2.3 or any other areas of the Safety Data Sheet (SDS) for your fragrance oil.
This may require you to include additional hazard statements.
Also, do NOT include any of the following statements:
- Non-toxic
- Non-harmful
- Non-polluting
- Ecological
- Anything indicating the fragrance oil isn’t hazardous
10. Unique formula identifier (UFI)
The UFI is a 16-digit code used by Poison Centers to rapidly identify the contents of your candle in the event of an emergency. On your label it’ll look like this:
UFI: E300-30P1-Y500-9212
Although technically the UFI is considered supplementary information, it’s a relatively new change to the CLP (Annex VIII).
Current guidance suggests the following if you’re including it:
- Keep near the hazard pictograms if possible
- Make it clearly visible, but there aren’t any specific font requirements
- Attach it to a fold-out label, tie-on tag, or an outer package if it isn’t already on the jar
Some Safety Data Sheets may include a UFI, but if you need to create one for yourself you can use the online tool provided by the European Chemicals Agency (ECHA).
If you’re creating a new UFI instead of using one from the SDS, submit it to the National Poisons Information Service.
UFIs are not required if you’re selling in the UK.
The GB CLP was apparently modified to remove this requirement, but that doesn’t mean you can’t do it if you want to.
Final Thoughts
It’s not unreasonable to freak out about how many things have to be on your label AND the fact that fragrance oils contain a lot of chemicals classified as hazardous.
Fragrance oil suppliers and manufacturers feel a lot more of the pain from EU and UK regulation since most of the information candle makers need has to be included in the Safety Data Sheets – a burden that falls exclusively on suppliers.
Safety Data Sheet development requires careful identification and classification of the different substances in a blend.
Groups like European Chemicals Agency (ECHA) and Health & Safety Executive (HSE) enforce and publish standards around hazardous materials and assist groups with interpretations of regulation (such as EU REACH and UK REACH).
Where should you put your label?
If you sell your candle inside a box or other “package”, that package also needs to have a CLP-compliant label (according to CLP Article 33).
The only exception is if you can see the candle’s CLP label through the outer packaging.
Without officially endorsing this, it seems many candle makers shove their CLP-compliance onto the safety sticker on the bottom of the candle jar, leaving their primary label less cluttered and prettier.
Whether that passes as an industry-accepted action remains to be seen, but it goes against the guidance provided by CLP Article 31 which says you need to be able to see all the CLP information when the candle is sitting normally (as in, not on the bottom).
Safety testing
Labels, however insane they may be to create, are not a substitute for great design.
Much like the United States, safety testing is an industry standard but not the law. The British Standards Institution (BSI) has three suggested procedures for testing candles, documented in their paid references:
…which is a subject for a different article since it doesn’t impact label design in any way.
Custom fragrance blends
If you want to blend fragrance oils, you won’t be able to make a CLP-compliant label without having a Safety Data Sheet made specifically for the literal custom blend.
Unfortunately, this is a huge barrier to creative development, but it’s the rules.
If you’re experimenting with blends from the same supplier, you can always reach out to them and ask if they can provide a relevant SDS for your blend.
Please report any mistakes or errors to hello@armatagecandlecompany.com.
