CLP label maker for candles and wax melts

When a candle or wax melt needs a CLP label

Candles, wax melts and reed diffusers are not cosmetics. The joint advice of the British Candlemakers Federation and Cornwall Council Trading Standards (January 2024) treats them as “mixtures” of wax, fragrance and colour under the CLP Regulation, and it is almost always the fragrance that makes a label necessary. Many fragrance ingredients are skin sensitisers. Above their elicitation limit, usually 0.1% of the finished product, the label needs EUH208: “Contains (name of sensitising substance). May produce an allergic reaction.” At higher levels, usually from 1%, the product is classified as a skin sensitiser and needs the full set of hazard information. An unscented candle with no hazardous ingredients needs no CLP label, though candles still carry fire-safety warnings under the separate standard BS EN 15494.

The classification is not something to guess. Your fragrance supplier must give you an SDS, and the advice pack asks makers to get one that matches the proportion they use, such as 10%, because the SDS for the neat oil lists hazards the finished candle may not have. Our fragrance allergen calculator shows how the percentages work.

What goes on the label

Article 17 of CLP lists the label elements for a hazardous mixture:

1. The name, address and telephone number of the supplier: you, if you sell the candle.
2. The nominal quantity for products sold to the public, unless it is shown elsewhere on the package.
3. The product identifier: the trade name, plus the substances that cause a sensitising classification (up to four names, unless more are needed).
4. Where applicable, the hazard pictograms, the signal word (“Warning” or “Danger”), the hazard statements (H-codes) and the precautionary statements (P-codes), all from section 2.2 of the SDS.
5. Supplemental information, such as EUH208 and, in the EU and Northern Ireland, the unique formula identifier (UFI) where one is required.

The label must be in the official language of each country where it is sold, firmly fixed to the packaging that directly holds the product, and readable horizontally when the package is set down normally (Article 31). Words such as “non-toxic”, “non-harmful” or “ecological” that contradict the classification are not allowed on the label or packaging (Article 25(4)).

Label and pictogram sizes

CLP Annex I, section 1.2.1 sets the minimum sizes by the capacity of the package. Great Britain's version has the same table.

On top of the table, each pictogram must cover at least one fifteenth of the label area given to the Article 17 information, and never less than 1 cm². Pictograms are squares set on a point, with a black symbol on a white background and a red frame. The preview applies all three rules and rounds the pictogram up to the next half millimetre, which is why a 52 × 74 mm label gets 16.5 mm pictograms.

Small packs have some relief. In packages of 125 ml or less, the hazard and precautionary statements for certain hazards may be left off, including skin and eye irritation (category 2) and aquatic chronic categories 1 and 2; for aquatic chronic categories 3 and 4 only the precautionary statements may go. Skin sensitisation (H317) is not on that list. Where the label cannot fit, CLP allows fold-out labels, tie-on tags or the full label on outer packaging with the essentials on the inner pack.

UFI: EU and Northern Ireland only

In the EU and Northern Ireland, a mixture classified as hazardous for health or physical effects must be notified to the poison centres before it is placed on the market (CLP Annex VIII), and its 16-character UFI goes on the label, written as “UFI:” followed by the code. A candle labelled only with EUH208, or only for aquatic hazards, is not classified for health or physical effects. Great Britain removed the UFI and poison centre rules from GB CLP at the end of 2023; the advice pack says GB sellers may voluntarily send their SDS to the UK National Poisons Information Service instead.

EU label rules due to change

Regulation (EU) 2024/2865 rewrote Table 1.3 for the EU with a minimum font size (an x-height of at least 1.2 mm for packages up to 0.5 litres) and other formatting rules. Regulation (EU) 2025/2439 deferred those rules: they are now due to apply from 1 January 2028. The Commission proposed simplifying them in 2025 (COM(2025) 531); as of 3 November 2026 no change to them had been published in the Official Journal. Until then the table above is the rule in the EU and Northern Ireland, and Great Britain's CLP is unaffected.

Step by step

1. Get the SDS for your fragrance at the load you use, and read section 2.2.
2. Copy the product identifier, pictograms, signal word and statements exactly. If an official statement offers a choice (“contents/container”), use the wording on your SDS.
3. Add the EUH208 names exactly as the SDS gives them.
4. Add your own name, address and phone number, and the nominal quantity.
5. Pick a label size, print a test copy at 100% scale, and measure the pictograms.

The advice pack also reminds online sellers that the same hazard information belongs on the product page, because CLP Article 48 covers advertisements; a photo of the label is the simplest way to comply. Making candles for Christmas markets in late November and December 2026? Check every new scent's SDS before the first market, not after.

Common mistakes

• Using the SDS for the neat oil. It can show pictograms your 8% candle does not need, or miss what it does.
• Printing EUH208 on a product already classified H317. The classified product names its sensitisers with the product identifier instead.
• Leaving out the phone number or address. All three supplier details are required.
• Shrinking the pictograms to fit a pretty label. Below 10 × 10 mm is never allowed.
• “Natural” or “non-toxic” claims next to a hazard label.

The pictograms in the preview are drawn by us to show placement and size. For production labels, use the official files from the UNECE GHS pictograms page. This page is general information, not legal advice; your SDS and your local trading standards or enforcement authority have the final word.