CLP Labels: The Complete UK Guide for Craft Sellers

If you sell candles, wax melts, reed diffusers, or room sprays in the UK, your products almost certainly need CLP labels. Fail to apply them correctly and you face trading standards enforcement, marketplace delistings, and potential criminal liability.

This guide covers what CLP labels are, which craft products need them, the six elements every label must include, and how to classify your products correctly.

This article covers UK (Great Britain) CLP requirements. Northern Ireland follows EU CLP, which has some differences. This is not legal advice — consult a qualified professional for your specific situation.

What Does CLP Stand For?

CLP stands for Classification, Labelling and Packaging. It refers to Regulation (EC) No 1272/2008, a set of rules governing how hazardous chemicals are classified and communicated to users through labels and safety data sheets.

Since 1 January 2021, the UK operates under GB CLP — the retained version of the EU CLP Regulation, adapted for Great Britain. The Health and Safety Executive (HSE) is the GB CLP agency responsible for regulation and enforcement.

The CLP system adopts the United Nations' Globally Harmonised System (GHS) for chemical classification. If you've seen those red-bordered diamond symbols on cleaning products — those are GHS hazard pictograms, and they're a core part of CLP labelling.

Which Craft Products Need CLP Labels?

The short answer: any product that is a chemical mixture and is classified as hazardous under GB CLP needs a compliant label. For craft sellers, this typically means:

Products that need CLP labels:

Candles — contain fragrance oils, which are chemical mixtures with known hazard classifications
Wax melts — same as candles; the fragrance oil concentration often makes them hazardous
Reed diffusers — usually contain higher fragrance oil concentrations than candles, so they often carry more severe hazard classifications
Room sprays — aerosol or pump sprays with fragrance compounds are chemical mixtures requiring CLP
Car fresheners, drawer sachets, and other home fragrance products — if they contain fragrance oils, they fall under CLP

Products that do NOT need CLP labels (but have other requirements):

Soap, skincare, and cosmetics applied to the body — regulated under the UK Cosmetics Regulation instead. You need a Cosmetic Product Safety Report (CPSR) and a notification to the UK responsible person, not a CLP label.
Toys — regulated under toy safety regulations (EN71 series). Some products like toy candles may need both CLP and toy safety compliance.
Unscented plain wax candles — if genuinely unscented with no fragrance oils, they may not classify as hazardous. Check the SDS for your specific wax.

The grey area: Some products sit at the boundary. A soap marketed as a hand wash is a cosmetic. The same soap marketed as a cleaning product falls under CLP. What matters is how the product is presented and its intended use.

The Six Required Elements on Every CLP Label

GB CLP labelling requirements specify six elements that must appear on every label for a hazardous mixture:

1. Product Identifier

The name or trade name of the product. For mixtures (which is what most craft products are), this means the trade name or designation of the mixture, plus the identity of substances contributing to the classification.

For a candle, this would be something like: "Lavender & Sage Scented Candle" followed by the names of the hazardous fragrance components (e.g., linalool, limonene, coumarin) that contribute to the classification.

2. Supplier Details

The name, address, and telephone number of the supplier responsible for placing the product on the GB market. Post-Brexit, this must be a UK-based entity. If you buy fragrance oils from an EU supplier, you are the person placing the finished product on the UK market — so your details go on the label.

3. Nominal Quantity

The net quantity of the product in the package, where it is supplied to the general public. For candles this is typically weight in grams; for diffusers it might be volume in millilitres.

4. Hazard Pictograms

The red-bordered diamond-shaped GHS symbols that visually communicate the type of hazard. Each pictogram has a specific meaning — see the next section for the ones most relevant to craft products.

The pictograms must be printed at a minimum size relative to the label area. For labels up to 125 ml/g, each pictogram must be at least 10 × 10 mm. Larger packages need proportionally larger pictograms.

5. Signal Word

Either "Danger" (for more severe hazard categories) or "Warning" (for less severe categories). Only one signal word appears on a label — if the product qualifies for both, "Danger" takes precedence.

Most candles and wax melts carry the signal word "Warning." Reed diffusers and room sprays with higher fragrance concentrations may require "Danger."

6. Hazard and Precautionary Statements

Hazard statements (H-codes) describe the nature of the hazard:

H226: Flammable liquid and vapour
H317: May cause an allergic skin reaction
H319: Causes serious eye irritation
H412: Harmful to aquatic life with long lasting effects

Precautionary statements (P-codes) describe how to prevent harm, what to do in case of exposure, how to store the product, and how to dispose of it:

P210: Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking.
P261: Avoid breathing dust/fume/gas/mist/vapours/spray.
P280: Wear protective gloves/eye protection.
P501: Dispose of contents/container in accordance with local regulations.

The exact H-codes and P-codes on your label depend entirely on the classification of your specific product. You cannot copy them from another seller's label — even if you use the same fragrance oil, different concentrations produce different classifications.

CLP Hazard Pictograms for Craft Products

Nine GHS hazard pictograms exist, but craft sellers typically encounter three or four:

GHS02 — Flame Indicates flammable products. May apply to candles, wax melts, reed diffusers, and room sprays depending on the flash point and flammable properties of the finished product — not just the raw fragrance oil. Whether your product triggers this classification depends on your specific formulation; check your product against the flammable liquid criteria rather than assuming it applies.

GHS07 — Exclamation Mark Indicates irritant or harmful products. Common when fragrance oils contain components that cause skin or eye irritation (e.g., linalool, limonene, citral). Many candle and diffuser products carry this pictogram.

GHS09 — Environment Indicates products hazardous to the aquatic environment. Some fragrance oil components are toxic to aquatic organisms. Whether your product needs this pictogram depends on the specific ingredients and their concentrations.

GHS05 — Corrosion Less common for craft products, but some fragrance components at higher concentrations can cause serious eye damage or skin burns. More likely to appear on reed diffusers than candles.

You determine which pictograms apply through the classification process — not by guessing or copying another product's label. Our free CLP Pictogram Finder can help you identify which pictograms apply to your product type.

How to Classify Your Products Step by Step

Classification is the process of determining which hazards apply to your product and at what severity. For a detailed walkthrough specific to candles and wax melts, see our CLP labelling guide for candle and wax melt makers. Here's the general workflow:

Step 1: Collect Safety Data Sheets (SDS) from your suppliers. Every fragrance oil, dye, and chemical ingredient you use should come with a Safety Data Sheet. The SDS contains the hazard classification data you need. If your supplier hasn't provided one, request it — they are legally required to supply SDS for hazardous substances and mixtures.

Step 2: Identify hazardous ingredients and their concentrations. From each SDS, note the hazardous components (Section 3), their classifications (Section 2), and the concentration ranges. Then calculate what percentage of each hazardous ingredient is present in your final product based on your formulation recipe.

Step 3: Apply the mixture classification rules. GB CLP provides rules for classifying mixtures based on their ingredients. For most craft products, this involves the additive method — you add up the concentrations of ingredients with the same hazard classification and check whether they exceed the threshold for that hazard category.

For example, if your candle's fragrance oil is 8% of the total product weight and the fragrance oil contains 15% linalool (classified as a skin sensitiser), then linalool is 1.2% of your final product. If the skin sensitisation threshold is 1%, your product is classified as a skin sensitiser.

Step 4: Determine the label elements. Once classified, the regulation tells you exactly which pictograms, signal word, H-statements, and P-statements apply. This is not a creative exercise — it's a direct lookup based on the hazard categories your product falls into.

Step 5: Consider whether you need a Unique Formula Identifier (UFI). Mixtures classified for health or physical hazards and supplied to consumers may need a UFI code on the label. The UFI is a 16-character code that links your product to its formulation data in a poison centre notification. Check the current HSE guidance on labelling requirements for the latest position on UFI codes in GB.

CLP vs Cosmetics Regulation: Which One Applies?

This is the single most common point of confusion for craft sellers who make both home fragrance and body care products.

The deciding factor is intended use:

Product Type	Intended Use	Regulation	What You Need
Scented candle	Ambient fragrance (not applied to body)	GB CLP	CLP-compliant label
Wax melt	Ambient fragrance	GB CLP	CLP-compliant label
Reed diffuser	Ambient fragrance	GB CLP	CLP-compliant label
Hand soap	Applied to skin for cleansing	UK Cosmetics Regulation	CPSR + SCPN notification
Bath bomb	Applied to skin	UK Cosmetics Regulation	CPSR + SCPN notification
Lip balm, moisturiser	Applied to skin	UK Cosmetics Regulation	CPSR + SCPN notification
Room spray	Ambient fragrance (sprayed in air)	GB CLP	CLP-compliant label

If you sell products in both categories, you need to comply with both regulatory frameworks — CLP for your home fragrance line, Cosmetics Regulation for your body care line. They are separate regimes with different requirements.

What Happens If You Don't Comply

CLP compliance is not optional. Placing a hazardous product on the GB market without a compliant label is a criminal offence.

Trading standards enforcement: Local authority trading standards officers enforce CLP for consumer products. They can conduct unannounced visits, purchase products covertly for testing, enter premises, and seize evidence including taking measurements, photographs, recordings and samples. They can issue improvement notices, withdraw products from sale, and pursue prosecution.

Court penalties: Violations can lead to unlimited fines and up to two years' imprisonment, depending on the severity and whether the case is heard in a magistrates' court or crown court.

Marketplace enforcement: Etsy, Amazon, and other online marketplaces increasingly require compliance documentation. Products without proper CLP labels risk delisting, and some platforms now proactively check for compliance before allowing listings in regulated categories.

Practical impact: Even without formal enforcement, selling non-compliant products exposes you to civil liability if a customer has a reaction to an unlabelled allergen or is harmed by an undisclosed hazard. The CLP label is your evidence that you did your due diligence.

Quick CLP Compliance Checklist

Use this to check whether your existing labels meet GB CLP requirements:

Every hazardous product has a label with all six required elements (product identifier, supplier details, nominal quantity, pictograms, signal word, H/P statements)
Classification is based on your actual formulation and your suppliers' SDS data — not copied from another seller
Supplier details on the label show a UK entity name, address, and phone number
Pictograms are printed at the minimum required size for your label dimensions
Signal word matches the highest severity hazard category on the product
All required H-statements and P-statements are present and correct for the classification
Hazardous ingredient identities are listed where required
If required, a UFI code is present on the label
Labels are legible, durable, and firmly affixed to the packaging
You retain records of your classification rationale and SDS documents

Not sure where your labels stand? Try our free CLP Label Checker to identify gaps. If any item fails, your label needs updating before the product goes on sale. If you're evaluating tools to help with this process, our guide to what to look for in a CLP label generator covers the seven features that matter most.