CLP labelling for wax melts, candles and reed diffusers in GB

CLP labelling for wax melts, candles and reed diffusers

CLP labelling for wax melts in Great Britain depends on the finished mixture, not the fragrance oil. If that mixture is classified as hazardous, Article 4 requires a CLP label before you place it on the market. A melt that is not classified as sensitising can still need EUH208 when a category 1 or 1B skin sensitiser is at 0.1% or more, or a category 1A sensitiser is at 0.01%. A product with no classified ingredient needs no CLP label.

Do you need CLP for candles and wax melts?

GB CLP covers manufacturers, importers, downstream users and distributors in Great Britain. Northern Ireland follows EU CLP.

Candles, wax melts, essential-oil candles and reed diffusers are mixtures under CLP. Article 1 excludes finished medicines, veterinary medicines, cosmetics, certain medical devices, and food or feed. Candles, melts and diffusers are not on that list. HSENI describes a candle as a mixture on a carrier, the wick. A Derry City and Strabane trading standards briefing groups scented candles, wax melts and reed diffusers together. That briefing applies EU CLP in Northern Ireland, so use the GB text for a GB label.

Blending fragrance into wax changes the composition, so Article 4 requires you to classify that mixture before sale. You can't copy the oil's classification onto the melt. Distributors, and downstream users who leave the composition unchanged, may use a classification made earlier in the supply chain.

Where to find the fragrance classification

Start with the fragrance supplier's safety data sheet. For a hazardous oil supplied for use at work, an SDS is required. UK REACH Article 31 requires it in English, free of charge, no later than first supply. You can also ask for an SDS for some unclassified mixtures, for example one with a category 1 skin sensitiser at 0.1% or more, or another health or environmental hazard substance at 1% or more.

Section 2.1 gives the oil's classification, and section 3.2 lists hazardous ingredients with concentration or range and classification. Self-classification applies to all mixtures. Scale those figures to the fragrance loading in the wax, then apply the Annex I criteria. Each hazard class has its own threshold.

The GB Mandatory Classification and Labelling List is legally binding in England, Scotland and Wales, but only for substances that have an entry, and it does not classify the finished melt.

What goes on wax melt CLP labels?

Wax melt label requirements, and the same candle labelling rules, come from Article 17 when the mixture is hazardous. Use the elements that apply:

• supplier name, address and telephone number
• nominal quantity on packs for the public, unless already shown on the pack
• product identifiers
• hazard pictograms
• signal word
• hazard statements
• precautionary statements
• supplemental information

The label must be in English. Product identifiers are the trade name plus the substances that drive listed health classifications, including skin sensitisation. A maximum of four chemical names is generally enough. If a signal word is required, use "Danger" or "Warning", never both. Where the corrosion pictogram applies, do not also use the exclamation mark for skin or eye irritation (Article 26).

Article 28 limits precautionary statements to six, unless more are needed for the nature and severity of the hazards. A consumer label needs one disposal statement, unless Article 22 does not require one. Article 25(4) bars "non-toxic", "non-harmful", "ecological" and any other statement inconsistent with the classification.

When EUH208 is required

Annex II 2.8 requires this line on a mixture that is not classified as sensitising, once a sensitiser is at or above the Table 3.4.6 level: "Contains (name of sensitising substance). May produce an allergic reaction."

The thresholds are 0.1% for skin sensitiser Category 1 or 1B, and 0.01% for Category 1A. If a specific concentration limit is below 0.1%, the trigger is one tenth of that limit. Article 25(6) also requires the product identifier and the supplier's name, address and telephone number. A website or an email does not replace the phone number. If the melt is already classified as sensitising, name any other sensitiser that reaches the same threshold.

Label size, layout and small packs

Affix the label firmly to the immediate packaging, readable horizontally when the pack is set down normally. You may print it on the pack, clearly and indelibly. Keep pictograms, the signal word, hazard statements and precautionary statements together, with supplemental information beside them.

For packs up to 3 litres, Annex I Table 1.3 asks for a label of at least 52 × 74 mm if possible. Each pictogram is at least 10 × 10 mm, and 16 × 16 mm if possible, and must cover at least one fifteenth of the label. Use a black symbol on white, a red frame, and a square set on a point. If the pack is too small or awkwardly shaped, Article 29 allows fold-out labels, tie-on tags, or outer packaging.

Annex I 1.5.2.1 lets you omit some hazard and precautionary statements where the contents do not exceed 125 ml, only for listed categories. Those include skin irritation category 2, eye irritation category 2, and aquatic acute 1 or aquatic chronic 1 or 2. Aquatic chronic 3 or 4 can drop precautionary statements only. Skin sensitisation is not listed, so this does not remove H317, and it does not remove pictograms, the signal word or supplier details where those apply. Check the current Annex I text before you rely on it.

The 125 ml cut-off is written in millilitres, which is an awkward fit for a melt sold by weight. Ask your local trading standards office how they apply it.

Packs for the public must not attract children's curiosity, mislead consumers, or look like food, medicines or cosmetics. The Derry and Strabane briefing also cites the Food Imitations (Safety) Regulations 1989 for melts shaped or scented like food.

GB, Northern Ireland and the US

Great Britain has no duty to create or submit a UFI, and the poison-centre data scheme is voluntary. The 21 May 2026 amendment did not change GB label elements, sizes or EUH208 (HSE).

Northern Ireland follows EU CLP, including a UFI in the supplemental information where Annex VIII requires one. Minimum font sizes under the revised EU rules, postponed to 1 January 2028, apply there and not in Great Britain (Regulation (EU) 2025/2439).

In Great Britain the General Product Safety Regulations 2005 still require a safe product, and warnings and packaging count. Northern Ireland moved to the EU General Product Safety Regulation on 13 December 2024 (GOV.UK). BS EN 15494:2019 is good practice for candle safety labels, not a CLP duty, and it is not on the GB list of standards that give a presumption of conformity.

US sellers do not use CLP. The CPSC requires cautionary labelling where a candle contains a hazardous substance under the Federal Hazardous Substances Act.

RegAffairs AI gives a cited answer to these questions, with links to the GB CLP provisions.