CLP vs Cosmetics Regulation — Which Applies to Your Products?
Many UK craft sellers make products that straddle the line between CLP-regulated chemical mixtures and cosmetics. Getting this wrong means applying the wrong compliance framework, which can lead to enforcement action, marketplace takedowns, or unsafe products reaching customers.
The simple test
Does your product go ON the body? (skin, hair, nails, lips, teeth, intimate areas)
Yes = UK Cosmetics Regulation. You need SCPN notification and a Cosmetic Product Safety Report (CPSR).
Does your product go IN the room or ON surfaces? (candles, wax melts, reed diffusers, room sprays, cleaning products)
Yes = UK CLP Regulation. You need CLP-compliant hazard labelling.
Products that fall under CLP
CLP (Classification, Labelling and Packaging) regulation applies to chemical mixtures — products that contain substances which could pose hazards. Common craft products under CLP:
- Candles and wax melts — contain fragrance oils classified as chemical mixtures
- Reed diffusers — high-concentration fragrance mixtures
- Room sprays and pillow mists — aerosolised chemical mixtures
- Cleaning products — household chemical mixtures
- Wax burner oils — concentrated fragrance mixtures
These products require CLP-compliant labels with hazard pictograms, signal words, H-statements, P-statements, and supplier details. CraftCert handles this classification and label generation.
Products that fall under cosmetics regulation
The UK Cosmetics Regulation applies to products intended to be placed in contact with the body for the purpose of cleaning, perfuming, changing appearance, or protecting:
- Soaps and bath bombs (if making cosmetic claims)
- Lotions, creams, and balms
- Lip products (lip balm, lipstick)
- Shampoos and conditioners
- Perfumes and body sprays
- Deodorants
These products require a Cosmetic Product Safety Report (CPSR) prepared by a qualified assessor, and notification via the UK Submit Cosmetic Product Notification (SCPN) system.
CraftCert does not handle cosmetics regulation or CPSR. If your product is a cosmetic, you need a qualified safety assessor. See the CTPA for guidance.
Grey areas — when it depends on the claim
Some products can fall under either regulation depending on how they are marketed:
- Soap — a soap marketed for “cleaning hands” is a cosmetic. The same soap marketed as a “decorative soap” or “room fragrance” may fall under CLP instead. The key is the intended use stated on the label.
- Bath products — a bath bomb marketed for skin benefits is cosmetic. A bath product marketed purely as fragrance for the room could be CLP.
When in doubt: if the product touches the body and makes any cosmetic claim (cleaning, moisturising, perfuming, etc.), treat it as a cosmetic. The penalties for getting this wrong are significant.
Key differences at a glance
| Aspect | CLP | Cosmetics |
|---|---|---|
| Applies to | Chemical mixtures for the room/surfaces | Products applied to the body |
| Label requirements | Hazard pictograms, signal word, H/P statements, supplier details | INCI ingredient list, CPSR reference, batch code, SCPN notification |
| Safety assessment | Self-classification from SDS data | CPSR by qualified assessor (typically £50-150 per product) |
| Enforced by | HSE, Trading Standards | OPSS, Trading Standards |
| CraftCert covers? | Yes | No |
What CraftCert does
CraftCert classifies your CLP-regulated products (candles, wax melts, diffusers, room sprays) based on the hazard data from your ingredient Safety Data Sheets. It generates compliant labels with the correct pictograms, statements, and supplier details, and maintains exportable classification records.
If you sell both CLP products and cosmetics, use CraftCert for your CLP products and work with a qualified safety assessor for your cosmetics.