Do You Need CLP Labels to Sell Candles in the UK or EU?

CLP is the chemical classification and labeling law. A CLP hazard label on a candle is needed only when the candle, as a mixture, is classified as hazardous, or when it holds a sensitizing substance from the fragrance at or above a tenth of that substance's limit. Wax is normally not classified, so the fragrance is the point to check. The numbers come from the supplier's safety data sheet (SDS). The EU and Great Britain now have separate versions. I am a candle maker, not a lawyer, so this is what the regulators say, not advice on your product.

What is CLP, and who runs it?

• EU: the EU CLP Regulation. ECHA, the European Chemicals Agency, publishes a fact sheet called "Complying with CLP when making or importing candles" (August 2024). It says candle products are chemical mixtures under REACH and CLP. CLP has changed since then: Regulation (EU) 2024/2865 added label formatting and distance sales rules, and in October 2025 the European Parliament voted to move their start to January 1, 2028. I did not read the final text, so check it.
• Great Britain (England, Scotland, Wales): GB CLP, run by the Health and Safety Executive (HSE). HSE says the EU CLP Regulation was assimilated into GB law and amended so it works there, and that Great Britain adopts GHS, the UN system behind CLP, independently of the EU.
• Northern Ireland: HSE says chemicals placed on the Northern Ireland market are under EU CLP. HSE Northern Ireland (HSENI) publishes its own candle page.

When does a candle need a hazard label?

ECHA says a candle's classification depends on the classification of its ingredients and their concentration in the final mixture, and the SDS from your fragrance and color suppliers is where to find it (Section 3). The usual issue is sensitization, meaning the fragrance may cause an allergic reaction. ECHA gives these limits:

• A skin sensitizer category 1A has a classification limit of 0.1 percent. Categories 1 and 1B have 1 percent.
• At or above the limit, the candle is classified as Skin Sens. 1. It then needs the hazard statement H317, "May cause an allergic skin reaction," plus the pictogram and precautionary statements.
• Below the limit, but at or above a tenth of it (0.1 percent of a 1B substance, 0.01 percent of a 1A), the label must say "Contains (name). May produce an allergic reaction." That is EUH208.

ECHA says a few very potent sensitizers have lower limits, though they are not common in candles. If the blend's parts are not listed, it says you may classify from the blend itself: a candle with 10 percent of a blend classified as sensitizing is likely over 1 percent.

Business Companion, which GOV.UK points businesses to, covers England, Scotland and Wales (candle guide last reviewed May 2024). It gives the same 0.1 and 1 percent figures for the usual case and says unscented candles often need no labeling.

Worked example: one fragrance oil

These numbers are made up. Real ones come from your oil's SDS. Say the candle is 7.4 percent fragrance oil by weight (8 g of oil per 100 g of wax: 8 / 108 = 7.4 percent).

• Oil A. The SDS lists a category 1B sensitizer at 5 percent of the oil. In the candle: 0.074 x 5 = 0.37 percent. That is under the 1 percent limit, so no H317. It is above a tenth of the limit (0.1 percent), so the EUH208 line is needed.
• Oil B. The SDS lists a category 1A sensitizer at 2 percent of the oil. In the candle: 0.074 x 2 = 0.148 percent. That is above the 0.1 percent limit for 1A, so the candle is classified Skin Sens. 1, and the full label applies.

I worked one substance at a time, as ECHA's limits read. HSENI words its 1 percent line as a total of sensitizing fragrance ingredients. Those do not read the same, so ask a helpdesk if your oil lists several.

What does the label have to look like?

ECHA says the label must be firmly affixed to the packaging that immediately holds the candle, on a side where the text reads horizontally. It also says a CLP label cannot go straight on the wax, and an open glass container, tea light foil or openwork paper box is not adequate packaging for a hazardous mixture.

In the EU, ECHA adds poison center notification and a UFI code on the label for a hazardous candle. For Great Britain, Business Companion says products with hazards must be notified to HSE within one month, and describes a UFI code. HSE's own GB CLP page, updated May 2026, says GB manufacturers and importers no longer have to notify HSE when placing "new" substances on the market. Those two do not line up, so ask HSE.

What other rules sit next to CLP?

• Candle safety standards. ECHA names three European standards, EN 15426 (sooting), EN 15493 (fire safety) and EN 15494 (product safety labels), which national authorities cover, not chemicals authorities. Business Companion lists the British versions as designated standards and says candles must be labeled to them, BS EN 15494 in particular, as well as to GB CLP.
• General product safety. GOV.UK says Great Britain has the 2005 regulations, and Northern Ireland has had EU regulation 2023/988 since December 13, 2024.
• Weight marking. Business Companion says that unless CLP labeling applies, a candle need not be marked with weight in Great Britain, and any weight shown must not mislead.

Do these rules reach a US maker?

I did not find a regulator page on a US maker shipping to a UK or EU customer. ECHA's sheet is written for companies based in the EU or EEA. HSE says a GB business buying from the EU and selling on the GB market is an importer. ECHA says the duty to classify lies mainly on the manufacturer or importer, but the duty to make sure a label is CLP-compliant lies with every supplier in the chain. Ask the national CLP helpdesk for your market.

Common mistakes

• Not keeping the fragrance oil's SDS.
• Using an old SDS after the supplier changes the oil.
• Mixing up the EU and the Great Britain rules.
• Treating a US warning label as a CLP label. They are different rules.

Questions

Do I need a CLP label on a small candle?

ECHA says certain labeling exemptions may apply to small candles but does not spell them out in the sheet. Ask a helpdesk about your size.

Do I need an SDS for my candle?

ECHA says a seller supplying a hazardous candle to professional users or to a retailer or distributor needs one, and that selling directly to consumers does not require passing one on. Business Companion says the same for Great Britain.