CLP (CLASSIFICATION, LABELLING AND PACKAGING) REGULATION
What is CLP?
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.
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 Westies Wax we provide your products with the CLP label at point of sale. You will find this information on every individual fragrance, here is an example of what you will see
Benzyl benzoate, Coumarin, Geraniol, Alpha-iso-methyl ionone,
Citronellol, Heliotropine, Benzyl Salicylate, Methyl cinnamate, Hexyl
cinnamaldehyde. May produce an allergic reaction. Toxic to aquatic life with
long lasting effects. Wash Hands after handling
10 Tower Street, Ludlow, Sy8 1LR
We also give a safety warning card for you to keep handy with all our details on
- Phone number
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
To make this clearer here is an example of one of our 10% CLP templates for our Apple fragrance oil and a short explanation of each element:
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.
The label present on our fragrance oil bottles is not a CLP template for products made using the oil, this label is the CLP for the pure 100% oil which is one of the many obligations that as suppliers we are duty-bound to meet. Your wax products need a CLP for the percentage of oil contained within them.
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.ht
The British Candlemakers Federation - http://www.britishcandles.org/?pages_id=23
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 28/06/2020