Q.01

Do wax melts need a CLP label in the UK?

Yes, if the wax melt is classified as hazardous. Under GB CLP, anyone who places a hazardous mixture on the market must label and package it before supply (Article 4(4)) [1]. Trading standards treat scented wax melts as CLP mixtures. A melt that contains no classified ingredients needs no CLP label. One that is not itself classified but contains a sensitiser still needs a short warning statement.

Why wax melts fall under CLP

  • GB CLP defines a "mixture" as "a mixture or solution composed of two or more substances". An "article" is an object whose shape or design determines its function more than its chemical composition does [2]. A melt is scented wax with no wick, heated to release fragrance, so it is the chemistry that does the job.
  • A Northern Ireland council trading standards briefing (Derry City and Strabane, December 2022) says CLP "includes products such as: Scented Candles, Wax Melts and Reed Diffusers". It says the wax itself is usually non-hazardous and the hazard comes from fragrance and colour additives. Each product with a classified ingredient needs its own tailored CLP label, and an unclassified one needs none (briefing pp. 2, 3, 8).
  • Wax melts are not on the list of excluded finished products in Article 1(5) (medicines, cosmetics, certain medical devices, food and feed) [3].

What triggers a label

  1. The mixture is classified as hazardous. You classify the finished wax-plus-fragrance mixture (Article 4(1)), and suppliers must then label it [1]. The label must show [4]:
    • the supplier's name, address and telephone number;
    • the nominal quantity, for products sold to the general public;
    • the product identifiers;
    • pictograms, signal word, hazard statements and precautionary statements;
    • any supplemental information;
    • all of it in English.
  2. The mixture is not classified but contains a sensitiser. If a sensitising fragrance substance is present at or above the Annex I Table 3.4.6 concentration, the label must carry EUH208: "Contains (name of sensitising substance). May produce an allergic reaction" [5]. That label must also give the product identifier and the supplier's name, address and phone number (Article 25(6)) [6].

Label and packaging rules once CLP applies

  • The label must be firmly fixed to the packaging that directly holds the product, readable horizontally, and clearly and indelibly marked (Article 31) [7].
  • Pictograms, signal word and hazard and precautionary statements must sit together (Article 32) [8].
  • Products for the general public need a disposal precautionary statement (unless Article 22 does not require one), and normally no more than six precautionary statements (Article 28) [9].
  • Claims such as "non-toxic" or "ecological" that contradict the classification are banned (Article 25(4)) [6].
  • Packaging for the public must not attract children's curiosity or look like food or cosmetics in a misleading way (Article 35(2)) [10]. The same briefing also points to the Food Imitations Safety Regulations 1989 for melts shaped or scented like sweets or fruit, which call for a "NOT FOOD, DO NOT EAT" warning (p. 35).
  • Small packs: if the pack is too small for a normal label, Article 29 allows fold-out labels, tie-on tags or outer packaging [11]. For contents of 125 ml or less, hazard and precautionary statements may be left out for certain listed hazard categories, including Skin Irritation Category 2 [12].

Great Britain vs Northern Ireland

  • Northern Ireland: the EU CLP text requires a unique formula identifier (UFI) in the supplemental label section where one is created under Annex VIII (Article 25(7)) [13]. The NI briefing lists the UFI among the label elements (pp. 11-12).
  • Great Britain: the GB CLP text shows Article 25(7) and (8) as omitted [6]. Under GB Article 45, any poison-centre information duty depends on regulations the Secretary of State makes under Article 45(4) [14].

Alongside CLP

  • The General Product Safety Regulations 2005 apply whatever the CLP classification. Producers may only place "safe" products on the market (regulation 5) [15]. Labelling, warnings and packaging count towards whether a product is safe (regulation 2) [16].
  • No OPSS chemical-product alerts or recalls mention wax melts or candles.

Approach: I read the GB CLP and EU CLP texts, the GB General Product Safety Regulations 2005 and the OPSS chemical-product alerts and recalls, plus the Derry City and Strabane trading standards briefing. I found no HSE page that deals with wax melts specifically.

Q.02

What has to go on the label?

If your wax melt is classified as hazardous under GB CLP, the label needs these eight things in English: supplier details, nominal quantity, product identifiers, pictograms, signal word, hazard statements, precautionary statements and any supplemental information (Article 17) [4]. If the melt is not classified but contains a sensitising fragrance substance, it needs a shorter label (point 2 below).

1. Full label for a classified melt (Article 17(1))

ElementWhat the text requires
SupplierName, address and telephone number [4]
Nominal quantityRequired for packs sold to the general public, unless it is shown elsewhere on the pack [4]
Product identifiersThe trade name of the mixture, plus the names of the substances that cause certain classifications: acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitisation, STOT or aspiration hazard. Usually up to four chemical names is enough. The name must match the one on the safety data sheet (Article 18(1), (3)) [17]
Hazard pictogramsTaken from the Annex I tables for each classification (Article 19) [18]. Precedence rules cut duplicates. For example, GHS07 is dropped for skin or eye irritation where GHS05 applies (Article 26) [19]
Signal word"Danger" or "Warning", never both (Article 20(3)) [20]
Hazard statementsWorded as in Annex III (Article 21) [21]. Every statement from the classification goes on, unless one clearly duplicates another (Article 27) [22]
Precautionary statementsChosen using Annex IV Part 1, with the product's use in mind (Article 22) [23]. Normally no more than six, and leave out any that are clearly redundant. Consumer products need one disposal statement covering the product and its packaging (Article 28) [9]
Supplemental informationAny EUH statements that Annex II triggers, plus label elements required by other law. Optional extra information is allowed if it does not contradict the classification. "Non-toxic", "ecological" and similar claims are banned (Articles 25 and 32(6)) [6][8]

If a classified melt contains other sensitisers above the Annex I Table 3.4.6 concentration, besides the one that caused the classification, the label must name those substances too [5].

2. Melt not classified, but containing a sensitiser

  • The label must carry EUH208: "Contains (name of sensitising substance). May produce an allergic reaction". This applies where the substance is at or above the Annex I Table 3.4.6 concentration [5].
  • It must also show the product identifier and the supplier's name, address and telephone number (Article 25(6)) [6].
  • Annex II 2.10 sets out when EUH210 ("Safety data sheet available on request") applies. That rule covers mixtures not intended for the general public, so it does not apply to retail melts [5].

3. Layout and format

  • Pictograms, signal word, hazard statements and precautionary statements must sit together. You choose the order of the statements. Supplemental information goes next to these elements (Article 32) [8].
  • The label must be fixed firmly to the packaging that holds the melts directly, and be readable horizontally when the pack is set down normally. The text must be clear and indelible. You can print the elements on the pack instead of using a separate label (Article 31) [7].
  • Pictograms are a square set on its point, with a black symbol on a white background and a red frame. Each one must cover at least 1/15 of the label area and be no smaller than 1 cm² [24].
  • For packs up to 3 litres, the label should be at least 52 × 74 mm "if possible". Each pictogram should be at least 16 × 16 mm if possible, and never smaller than 10 × 10 mm [24].
  • If the pack is too small or awkwardly shaped, Article 29 and Annex I section 1.5 allow fold-out labels, tie-on tags or reduced label content [11].

4. Packaging extras that depend on the classification (consumer supply)

  • A tactile warning is needed if the melt is classified for any of the hazards listed in Annex II 3.2.1.1. These include acute toxicity, skin corrosion, respiratory sensitisation, aspiration hazard and flammable solids [25].
  • Child-resistant fastenings are needed for acute toxicity categories 1 to 3, STOT category 1 or skin corrosion category 1 [5].
  • A melt with typical skin and eye irritant or sensitiser classifications needs neither of these.

Northern Ireland: the label also needs the UFI under EU CLP Article 25(7). GB CLP shows that paragraph as omitted [13][6].

Approach: I read the GB CLP labelling articles (Articles 17 to 32) and the relevant parts of Annexes I and II on legislation.gov.uk. The exact pictograms and statements for your melt depend on your mixture's classification, which comes from its fragrance's ingredients.

Q.03

Where do I find the classification for my fragrance oil?

Your fragrance oil's classification is in Section 2 of the safety data sheet (SDS) your supplier has to give you. Section 3 of the same SDS lists the hazardous ingredients with their concentrations and classifications, and those are the figures you need to classify your finished wax melt. You can't just copy the oil's classification onto the melt: the oil is diluted in wax, so the melt is a different mixture and has to be classified itself.

Your supplier's duties (UK REACH Article 31)

  • An oil that is classified as hazardous under CLP must come with an SDS laid out as in Annex II (Article 31(1)) [26].
  • If the oil is not classified, the supplier must still give you an SDS when you ask, as long as it contains at least one of these:
    • a skin sensitiser category 1 at 0.1% by weight or more, or certain other listed hazards at that level;
    • any substance posing a health or environmental hazard at 1% or more (Article 31(3)) [26].
  • The SDS must be in English and dated (Article 31(5)-(6)) [26].
  • It must be free, on paper or electronically, and arrive no later than the first delivery. The supplier must send you a revised version "without delay" when new hazard information becomes available (Article 31(8)-(9)) [27].

What to read on the SDS

  • Section 2.1 gives the oil's classification under the CLP criteria. If the oil doesn't meet the criteria, the SDS must say so clearly. If the hazard statements are only given as codes, the full wording is in Section 16 [28].
  • Section 3.2 gives each relevant ingredient's identifier, concentration (or concentration range) and classification. Where a range is given, the hazards are based on the highest concentration in that range [29].

Classifying the melt yourself

  • If you place the melt on the market, GB CLP makes you a downstream user, and you must classify it before you sell it (Article 4(1)) [1].
  • You do this by applying the Annex I criteria for each hazard class to the information you have (Article 9(1)) [30]. In practice, you take the Section 3 ingredient percentages, scale them down to the oil's loading in the wax, and compare the results with the Annex I thresholds. For example, this is how you decide whether EUH208 or a Skin Sens. 1 classification applies to the melt.

Checking a single ingredient

  • The HSE's GB Mandatory Classification and Labelling List (GB MCL) is the legally binding harmonised classification under GB CLP. It works like EU CLP Annex VI and is searchable by CAS or EC number. For example, its entry for 1-phenylethan-1-one (1-phenylethylidene)hydrazone (CAS 729-43-1) reads Skin Sens. 1, H317, GHS07, "Warning" [31].
  • The GB MCL only covers substances with a harmonised entry. For anything else, rely on the supplier's SDS.

If you send me the SDS (or just the Section 3 list) and your fragrance loading, I can look up each ingredient on the GB MCL and work through the melt's classification.

Approach: I read UK REACH Article 31 and Annex II, GB CLP Articles 4 and 9, and the HSE GB MCL List. I didn't search the EU sources (EU REACH, EU CLP Annex VI), which would matter for Northern Ireland supply.

Q.04