Do IFRA Limits Apply to Essential Oils in Candles?

Yes. "Natural" is not a way around IFRA. IFRA's guidance covers essential oils through the restricted substances they contain, and some natural materials have an IFRA Standard of their own. A ban also applies in candles: IFRA says a ban "applies to all final product applications, including non-skin contact applications." I am a candle maker, not a lawyer or a chemist, so for any oil you plan to sell, ask your supplier for its composition and conformity information.

How are essential oils covered by IFRA?

IFRA's guidance says its Annex on contributions from other sources gives "indicative levels of restricted substances" in a list of complex natural ingredients, "including essential oils." Those levels let a company work out how much of an oil it can use while keeping each restricted constituent under its limit. If a company has analytical data for the exact oil, that data can be used instead of the typical levels.

Some natural materials also have a Standard of their own. The guidance's example is ylang ylang. In that case IFRA says there are two restrictions to compare, the one from the oil's constituents and the one for the oil itself, and "the lowest one will drive the maximum allowed use."

Why doesn't my essential oil come with an IFRA certificate?

IFRA's guidance addresses this directly. When there is an IFRA Standard on a raw material (it gives citrus essential oil as an example), "the supplier should not issue an IFRA certificate as such." Instead, suppliers "should communicate to their clients the conformity of the raw material with the corresponding IFRA Standard in a different format."

IFRA adds that if an essential oil is used as such in the finished product, the supplier should make sure the constituents that have an IFRA Standard do not exceed the concentration limit in the finished consumer product. So a missing certificate is not a red flag by itself. What to ask your supplier:

• Does this oil have its own IFRA Standard?
• Does it contain constituents with IFRA limits, and at what levels?
• What is the most I can use in a candle (Category 12), and which Amendment is that based on?

If the answer is a statement or a composition sheet, keep it with your records like a certificate. If the supplier cannot tell you, that is your answer on whether to use the oil in products you sell.

What about citrus oils and skin?

IFRA's guidance says phototoxicity considerations do not apply to non-skin contact products, "i.e., Category 12", so IFRA sets no phototoxicity restriction on candles. It matters for skin products, and possibly for diffusers: IFRA's 52nd Amendment letter says the phototoxicity limit for Category 10B, where reed diffusers are expected to move, is to match rinse-off products (50 ppm), with the final placement of diffusers set in the Notification. Candles are Category 12, and other restrictions and bans still apply.

Worked example: an essential oil limit in an 8 oz candle

All numbers are made up. Say the supplier of "EO-Y" states its limit in Category 12 is 3.00 percent of the finished product. IFRA states limits as weight-per-weight percent of the finished product, so the most load you can use, as a percent of the wax weight, is 0.03 / (1 - 0.03) = 0.03 / 0.97 = 3.09 percent (computed).

For a jar with an 8 oz total fill:

• Wax: 8 / 1.0309 = 7.76 oz
• Oil: 7.76 x 0.0309 = 0.24 oz
• Check: 0.24 / 8 = 0.030, or 3.0 percent of the finished candle

Compare that with your wax's maximum fragrance load from its sheet. If the wax would allow more, the oil's lower limit wins: stay under the lower of the two. The guide on which limit wins, IFRA or the wax maximum walks through both directions.

Common mistakes

• Assuming natural means safe or unlimited. IFRA treats essential oils as sources of restricted constituents, and some have their own Standard.
• Using an essential oil and a fragrance oil together without checking both. See how to check the limit when blending.
• Expecting a fragrance-oil style certificate for an essential oil that has its own IFRA Standard. Ask for the conformity statement and composition instead.
• Using "natural" or "non-toxic" on a label because the scent comes from essential oils. See non-toxic and clean candle claims.