CLP Labelling Guide: Step-by-Step for Candle and Wax Melt Makers
You know your candles and wax melts need CLP labels. But the regulation doesn't hand you a label — it hands you classification rules and expects you to work out what goes on your product. This guide walks through the actual process, from reading your fragrance oil's Safety Data Sheet to producing a finished, compliant label.
If you're new to CLP, read our CLP labels pillar guide first for the full regulatory background.
This guide covers GB CLP requirements for candles and wax melts sold in Great Britain. This is not legal advice.
Step 1: Gather Your Safety Data Sheets
Every fragrance oil and essential oil you use should come with a Safety Data Sheet (SDS) from your supplier. The SDS is the starting point for everything — it tells you what hazardous substances are in the oil and at what concentrations.
What to look for in the SDS:
- Section 2 (Hazards identification): The overall classification of the fragrance oil itself — hazard categories, H-codes, and pictograms
- Section 3 (Composition/information on ingredients): Individual hazardous components, their CAS numbers, concentrations (often given as ranges like 1–5%), and their individual classifications
- Section 11 (Toxicological information): Specific hazard data that feeds into classification
If your supplier hasn't provided an SDS, request one. They are legally required to supply Safety Data Sheets for hazardous substances and mixtures.
Keep every SDS on file. If trading standards ask how you classified your product, the SDS is your evidence.
Step 2: Calculate Your Ingredient Concentrations
Your finished candle or wax melt is a mixture of wax, fragrance oil, dye, and potentially other additives. CLP classification is based on the concentration of hazardous ingredients in the final product, not in the raw fragrance oil.
Example calculation:
Your candle recipe uses 8% fragrance oil by weight. The fragrance oil's SDS (Section 3) lists:
- Linalool: 10–15% of the fragrance oil → 0.8–1.2% of your candle
- Limonene: 5–10% of the fragrance oil → 0.4–0.8% of your candle
- Coumarin: 1–3% of the fragrance oil → 0.08–0.24% of your candle
These final-product concentrations are what you compare against the CLP classification thresholds.
Why this matters: A fragrance oil might be classified as a skin sensitiser at full strength. But once diluted in wax to 8% of the total product, the skin-sensitising components may fall below the classification threshold. You cannot simply copy the fragrance oil's classification onto your candle — you must recalculate for your specific formulation.
Step 3: Classify Your Product
Using the concentrations from Step 2, apply the GB CLP mixture classification rules to determine which hazard categories apply to your finished product.
Common classifications for scented candles and wax melts:
| Hazard | Typical Trigger | Threshold | Typical Result |
|---|---|---|---|
| Flammable liquid (H226) | Fragrance oil flash point | Depends on finished product flash point and concentration | Possible — depends on whether the finished product (not just the raw oil) meets the flammable liquid criteria |
| Skin sensitisation (H317) | Linalool, limonene, citral, eugenol above threshold | ≥ 1% (Category 1) or ≥ 0.1% (Category 1A) | Common at 8%+ fragrance loads |
| Eye irritation (H319) | Fragrance components irritating to eyes | Additive calculation ≥ 10% or individual ≥ 3% | Less common for candles, more common for diffusers |
| Aquatic toxicity (H411/H412) | Certain fragrance components | Additive calculation ≥ 25% (chronic category 3) | Some formulations, depends on specific oils |
The additive method: For most hazards, you add up the concentrations of all ingredients that share the same hazard classification. If the total exceeds the classification threshold, your product carries that hazard.
If your fragrance oil contains 0.9% linalool (skin sensitiser Cat 1) and 0.3% limonene (skin sensitiser Cat 1) in the final product, the combined total is 1.2% — which exceeds the 1% threshold for skin sensitisation Category 1.
Step 4: Determine Your Label Elements
Once you know your product's classification, the label elements follow directly from the regulation:
Signal word: "Warning" for most candle and wax melt products. "Danger" only applies if the product falls into more severe hazard categories (uncommon for candles at standard fragrance loads).
Pictograms: Determined by the hazard categories. Use our free CLP Pictogram Finder to see which pictograms apply to your product type. A typical scented candle label might show:
- GHS07 (exclamation mark) — for skin sensitisation and/or eye irritation
- GHS02 (flame) — if the finished product classifies as flammable based on its own properties, not just the raw fragrance oil's classification
H-statements and P-statements: Selected directly from the classification. Only include the statements that apply to your product's specific hazard categories — do not add extras "just in case."
Step 5: Lay Out Your Label
A CLP-compliant label for a candle or wax melt must include all six elements described in our complete CLP guide:
- Product name — your trade name plus the identities of the hazardous components contributing to classification (e.g., "contains: linalool, limonene")
- Your details — UK business name, address, and telephone number
- Net weight — typically in grams for candles and wax melts
- Hazard pictograms — minimum 10 × 10 mm for packages up to 125 g. Printed in red on white with a red border. Each pictogram must be clearly visible and not obscured by other label elements.
- Signal word — "Warning" or "Danger," printed prominently
- H-statements and P-statements — the exact codes and wording from the regulation
Label placement: The label must be firmly affixed to the product packaging, easily legible, and in a horizontal position. If your packaging shape makes direct attachment impractical (e.g., a small wax melt clamshell), you can use a swing tag — but the same requirements apply.
Language: Labels for products sold in Great Britain must be in English.
Step 6: Record Your Classification Rationale
This step is often skipped, and it's the one trading standards will ask about first. Document:
- Which SDS documents you used (keep copies)
- Your concentration calculations
- How you applied the classification rules
- Which hazard categories your product falls into and why
- The date you performed the classification
If you reformulate a product — change the fragrance oil, adjust the fragrance load, switch wax types — you need to repeat this process. A different formulation can produce a different classification.
Already have labels? Use our free CLP Label Checker to verify they include all required elements.
Common Mistakes to Avoid
Copying another seller's label. Even if you use the same fragrance oil from the same supplier, your product's classification depends on your specific concentration. A candle at 6% fragrance load may classify differently from one at 10%.
Using the fragrance oil's classification directly. The SDS classification applies to the neat oil, not your diluted product. You must recalculate for your final formulation.
Missing the "contains" line. If your product is classified for certain health hazards, you must name the specific substances that trigger the classification on the label. "Fragrance oil" is not sufficient — you need the chemical names (linalool, limonene, etc.).
Ignoring reformulations. Changed your fragrance oil supplier? Adjusted the fragrance percentage? Added a new dye? Each change potentially affects classification. Check every time.
Sources
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