So this is something we did a while back and I thought that perhaps it would benefit from being revisited and updated.
Everything below is still an up to date assessment of candle labels for UK and EU sales but given the popularity of fragrance blends, overpours and embeds I thought it would be useful to add an update on how these should be labelled.
Yes, you did read it correctly, is your candle legal? Are your wax melts safe? Do you know what to look for in a safe home fragrance product?
Most people when asked those questions would simply say “I don’t know” or “how can a candle even be illegal?”
Its fair to say that many in the UK and EU have no idea of the rules and regulations on candle safety and even fewer people know about the laws that came into effect in 2015.
From 1st June 2015 the CLP (Classification, Labelling, Packaging) regulations came into force which essentially means that anyone who sells scented candles, wax melts, room diffusers etc MUST comply with new legislation around labelling. This states that anything which is designated a mixture (in essence for the purposes of candles etc, it means anything with fragrance and/or dye) must be labelled in accordance with CLP regulations.
So what does CLP require?
CLP labelling is different to the candle safety labels that many of us will have seen with the simple illustrations and candle safety warnings, which are generic. Under the new rules every candle (or melt or diffuser) will have a different label explaining the specific hazards present and which are largely determined by the fragrance content. This is specific to the fragrance/dye and the fragrance/dye quantity used in the finished product
The provision of this is a LEGAL REQUIREMENT and is not optional.
Each label should include:
- Fragrance name
- Manufacturer name
- Manufacturer contact details – address, email, phone (in the event that someone develops a reaction to a chemical the authorities need to be able to contact the “responsible person” so generic details will not suffice
- Allergens present in product
- Warning symbol/pictogram
- Instructions of “what to do in the event of..”
Although many people have interpreted the rules as that melts do not apply, that is incorrect. As small products (under 125ml) full CLP does not need to be included however the bulk of the information above does still need to be present on any label.
Looking at many small candle and melt producers on Instgram, Facebook etc its pretty apparent that they do not understand the CLP laws and do not comply with them – to be honest there are a number of candle/melt reviewers/bloggers who do not appear to understand the rules either. If someone is promoting a scented product surely it is incumbant on them to ensure that that Company abides by all necessary rules and that the products they endorse are safe for the public?
So anyone who is involved in the business of selling candles/melts/diffusers get yourself up to speed with the CLP regulations and make sure that you understand how they apply to the products you sell/endorse. The rules have been established to create a level playing field and although, as usual, some of the huge candle companies have found a loophole, the laws do apply to most everyone else!
And if you are buying a candle or a cute set of melts, do please check that the person you are buying it from has full legal labelling on their products and that they understand their responsibilities – at the end of the day, if someone has an allergic reaction to a product that someone has sold, there will be a liability issue which will in all probability be excluded from any insurance.
This is by no means a comprehensive set of instructions on CLP and there are plenty of people out there far more legally proficient than us at explaining the rules – we just felt that we should make sure more people understood the law pertaining to candles/melts.
Thanks for reading!
OK, so IG and FB are full of custom blends and melts using overpours and its struck me that I couldn’t see how any of these were complying with CLP. Having asked a few vendors how they labelled things it became clear – they WERE NOT following the law.
According to the regulations (please see above) each and every fragrance blend MUST have its own SDS (Safety Data Sheet) which in turn is used to create the CLP label. You cannot use the CLP for each separate fragrance and put them on a product in a list – it is not compliant.
Let me give you an example – a custom blended melt bar containing strawberries and raspberries with a vanila overpour.
Each of the fragrance oils (or essential oils) has its own specific set of allergens which are present at maximum usage levels so hypothetically lets say
Strawberry has A1 at 0.4%
Raspberry has A1 at 0.5%
Vanilla has A1 at 0.25%
If the label was written based on this, each individual fragrance would be under the maximum usage level of say, 1%. However when the fragrances are combined the total of allergen A1 is 1.15% which could be sufficient to trigger an allergic reaction.
You cannot label wax melts or candles by using the list method, it is not accurate and is potentially illegal. Furthermore, if your labels are incorrect and someone has an allergic reaction and sued you, your insurance policy (PLEASE PLEASE PLEASE – make sure you have insurance before you start selling to ANYONE!) could be rendered invalid and you would then become personally liable. NOT to mention the Tading Standards investigation that could follow.
If you are buying candles, melts etc, please make sure that you understand who you are buying from and that they have the correct labelling – just because someone is on Facebook or has an Etsy shop does not make them a compliant business. If you have a reaction to a scented product, take some time to look at the label and try to understand which ingredient you have reacted to, in doing so you could save yourself another reaction but also if you know which ingredient affects you, you can avoid it and still enjoy your candles!
Any questions do please drop me a line and I will try to help!