Melt Burners

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?

Crazy Cat Lady Soy Wax Melts

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!

Update 2017

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.

Cherries and Berries Wax Waffle Melts

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!

 

 

26 Comments

        • Lucy

          Hi

          So I’m starting to make wax melts which I will hopefully be selling soon. This will just be to work mates etc. I need to make sure everything I am doing is ok with regulations, so if I get the safety stickers and put them on packaging of melts is this ok? Thank you

          • Ted Yates

            Hi Lucy

            If you are selling you will need more than safety stickers which are generic.

            You need fragrance specific CLP labels which detail the allergens for each specific fragrance at the percentage used. You will also need to ensure you have Product Insurance.

            The laws have changed and all wax products now must, by law, have the correct information. If anything happened with one of your products you would at best invalidate your insurance and at worst be liable personally for any damages.

            HTH

  • Lisa

    Hi I make scented candles in a wine glass but I do not make the wax I buy shop scented candles, melt it then redesign it. I’ve got CLP lables is that all I need ? I’m getting a bit confused .

    • LilyLou

      Hi Lisa

      So you buy ready made candles and remelt them? As you are selling (I presume you are selling) you will still need to provide a CLP label for each fragrance type. The label must list all the ingredients and the allergens – it is more than the warning labels you often see on eBay or Amazon.

      HTH

  • Hello. I am BRAND NEW into the candle making industry. I’m wanting to put jewellery inside the the candle as a ‘surprise’ when it’s melted (like the imperial candle concept). I’ve read this but I’m utterly baffled. Any chance of being able to private converse regarding the legal requirements etc?

    Thank you!

  • Gill

    Hello, I am a hobbyist and don’t intend to sell my candles. If I give away candles as gifts, would I need to include CLP labels for them?
    Thanks,
    Gill

  • Can I please ask a quick question. I notice you said the legal limit for chemicals is 1%.

    A previous document I read said that anything over 1% means the chemical must be named on the clp and anything under 1% the chemical doesn’t need to be named but it’s hazards do.

    I’m not sure if this makes sense but I hope it does x

    • Ted Yates

      Hi

      Not entirely sure what you mean but my understanding is that 1% is the limit when calculating the CLP and that any component part that is below 1% does not need to hghlighted as an allergen but still needs to be listed as part of the ingredients.

      Does that help?

  • Inga Guzun

    Hello, I have started a research about legal requirements for selling candles in UK. I would like to make and sell cup cake candles, but I was really disappointed reading that is illegal to sell proucts that:
    have a form, odour, colour, appearance, packaging, labelling, volume or size which is likely to cause persons, in particular, children to confuse them with food and in consequence to place then in their mouths or suck them or swallow them; and
    b) where such action as is mentioned in a) above is taken in relation to them, may cause death or personal injury.
    Could you, tell me, please, do I have any chance to sell cupcake and ice-cream candles? Thank you!

    • Ted Yates

      Hi

      The rules relate to Food Imitation and apply to all products including candles, soap, toys. In general I would say its not worth going dowm that route as you would be breaking the law before you start.

      TBH I would think about something else.

  • Inga Guzun

    Thank you! What about making the candle from soya beans, so the cupcake candle would be from a natural food product and if a child would eat it by mistake, it certainly would’nt harm the child as opposed to paraffin candle.

    • Ted Yates

      Then it would need to be foodsafe – all of the ingredients would need be foodsafe and it would be treated as a food.

    • Inga Guzun

      What do you think about making cupcake candles in UK, but selling them abroad on the websites like etsy or ebay. Is it illegal too? Thanks for help

      • Ted Yates

        I think you need to speak to Trading Standards, I cannot give you legal advice all I can do is provide my interpretation of the rules as I understand them.

        If you are selling to any of the coutries within the EU you are governed by the same rules as selling in the UK. The same would be true for foodstuffs.

        If you are thinking of changing your wax to soya that suggests you have not finished developing your product nor have you carried out full product testing – you cannot just change the wax and expect everything to perform the same. I would suggest you rethink your idea and come up with something else.

        Be aware that if you sell candles that are not allowed owing to Food Imitation rules, trading standards can stop you selling, seize your products or prosecute. They are very tough on products that they think may pose a rise to small children. I know of several interent sellers who have been visited by TS and have had action started against them. They have had to start all over again with a completely new product line.

        HTH

  • Katie

    Hi, i new to making wax melts. Currently practicing but hoping to sell in future. This clp and sds im finding rather confusing. The sds forms do we get that from the company we get fragrance from? Also im making wax melts so does my label need ingredients listed or is it just the scent with warning and my address? Thanks in advance. Katie

    • Ted Yates

      Hi

      Yes the company selling the fragrance should provide you with the SDS which you can then use to create your CLP.

      As far as wax melts are concerned they are generally under 125g and so they need the reduced CLP and not the full version but they still need the ingredients, warnings and pictograms. Oh and your contact details.

      HTH.

  • Denise

    Thank you for this very informative.
    I sell bath & body products so know all about labeling, record keeping and the legal side of selling products. I’m considering venturing into candle making so the allergen side of essential oils is quite straight forward for me. Should I keep a product file similar to what I do for my other products and if trading standards came calling is this the sort of thing they would expect to see for candles?
    Many thanks

    • Ted Yates

      Although the record keeping is similar, the labelling is completely different – you will need to create a CLP label (with an SDS) for every fragrance and at whatever varying percentages you use.

      The labels are not simply a list of allergens as you are creating a mixture with every blend you create so it would researching CLP/SDS before you start. ALso, EOs are tricky with candles so be prepared to undertake lots of testing to get your wick, wax and fragrance combination right.

Leave a Reply

Your email address will not be published. Required fields are marked *