CLP can be very tricky and time consuming, but, if you are selling wax melts and candles you need to make sure your business is compliant.
If you are part of any online wax communities you'll find there are so many opinions on what's right and what's wrong. You should really avoid this.
It's important to take the time to understand it yourself based on the ECHA Guidance. You can then be confident your business is compliant.
In this article we briefly cover what CLP is, why you need to be compliant and the things to look out for on your CLP label.
What is CLP?
CLP is the abbreviation for the legislation around labelling products that contain chemicals that could be harmful.
The full name for this is Classification of Labelling and Packaging legislation (EC) No 1272/2008.
CLP is needed to be on all home fragrance products (such as wax melts, candles, room sprays, reed diffusers etc) that contain any fragrance or essential oils.
This means the final products and at point of sale meaning your website or social media depending on your method of sale.
However, not every CLP label is the same, some require pictograms (warning symbols) and others don't. It's all around the ingredients of the oils and what warnings they trigger at the volume you are selling.
Why is it important to ensure my business is following CLP regulations?
CLP regulations are important to follow not only because it is a legal requirement but because of the dangers and harm that could be caused to a customer should they have an adverse reaction to a product which has not been labelled correctly.
All home fragrance products that are sold or gifted to anyone, family or stranger, need to have the correct labelling information to ensure that the person receiving the product is made fully aware of any allergens that could be triggered.
This is also important because sometimes people have reactions without knowingly being allergic to anything and having the information on the product will give the customer the ability to identify what is causing the reaction but also in severe cases can assist medical professionals to correctly treat the person.
It is important to note that not all fragrance oils have allergens that can trigger reactions, and every oil will have a different CLP label with unique details specific to that particular fragrance.
Depending on the size of the finished product you may be able to leave certain elements off the label if you are unable to fit all the information on or if it is a difficult size. Full details on this can be found in the legislation.
What do I need to put on the labels?
Every CLP label needs to have the following information: product identifier, allergen information, signal word, pictograms, hazard and precautionary statements, supplier details and business name.
Product identifier is the name of the fragrance such as ‘Autumn Raspberry & Amber Rose’.
Allergen information is the part of the label that lists all the ingredients that can cause a reaction and usually starts with the words contains, such as: Contains 1-(1,2,3,4,5,6,7,8- Octahydro-2,3,8,8-tetramethyl-2-naphthalenyl)ethanone, 4-tert-Butylcyclohexyl acetate Geranyl acetate, Hexyl salicylate, Linalool, alpha-iso-Methylionone, dl-Citronellol.
(Found under supplementary information on the 10% help sheet and in brackets on the product identifier).
Signal word is important as this highlights how dangerous the product can be to the end user. Words such as danger and warning are most often used. Autumn Raspberry & Amber Rose has a signal word of: Warning.
Hazard statements are important to list to give the full information to the customer. For this example the hazard statements are: May produce an allergic reaction, Harmful to aquatic life with long lasting effects and may cause an allergic skin reaction.
Precautionary and general statements are also included on the label such as: Dispose of contents/container to approved disposal site, in accordance with local regulations. Keep out of reach of children.
Pictograms are very important on a CLP label and they must be in full colour (red) and a minimum of 1cm along each line.
- Your business name, number and address must be present on the label as you are the one creating the product and are the one responsible for placing this product on the market.
Certain labelling exemptions apply e.g. to substances and mixtures contained in packaging that is small (typically less than 125ml) or is otherwise difficult to label. You can find more information regarding this on page 51 here.
It's a complicated subject, but CLP is something you need to understand.
Following these basic steps will help you on your way. As well as the assistance we have provided in the article it is important you have an understanding of the legal aspects of the CLP legislation and can use a basic knowledge to ensure your business is complying with the regulations.
You can read the ECHA Guidance here.
If you would like any assistance in creating your CLP labels or would like to clarify anything in this article please don’t hesitate to contact us either by email or phone and we would be happy to help.
You'll be glad to know that all of our fragrance oils come with CLP labels completely ready with your business information so you can simply fix them to your candles and wax melts
Thank you for reading, we hope this has been helpful.