CLP legislation explained

One of our most asked questions at the moment regards CLP.

As many of our customers are candle makers this article will hopefully provide a bit of clarity around these regulations and help ease the confusion a little.

What is CLP?

CLP is the Classification, Labelling and Packaging Regulation or to give it its full name REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 December 2008 on classification, labelling and packaging of substances and mixtures.

CLP sets detailed criteria for the labelling elements: pictograms, signal words and standard statements for hazard, prevention, response, storage and disposal, for every hazard class and category. It also sets general packaging standards to ensure the safe supply of hazardous substances and mixtures.

Basically it is an EU law that applies to ‘mixtures’ that are not cosmetics made or sold within the EU, and since 2015 now includes products such as Scented Candles, Wax Melts and Reed Diffusers. Its objective is to harmonise the labelling of products across the EU.

Reed Diffuser- for recipe click here

Can I just use the same CLP label for all my candles?

No.

Any mixture, for example wax mixed with a particular fragrance,  will have its own Hazard and Precautionary statements depending on the ingredients within the fragrance, unfortunately, this means that that labels are not interchangeable between products and each “mixture” will need its own tailored CLP label.

The concentration of the fragrance within the candle will also affect the statements needed, so a candle with 5% fragrance may need a different label from a candle using the same fragrance at 10%.

 

What do I need to do?

If you are making and selling candles you are responsible for having a relevant CLP label for each and every one of your products. , if your products do not comply with the necessary rules, you will almost certainly find that your insurance becomes invalid.

If the candle is not classified (i.e. it DOESN’T contain any ingredients that are classified as hazardous) then there is no requirement for it to be labelled in accordance with CLP.

Wax melts ‘coming soon’ from Sophie at ‘Made at Milldown’ 

Many ingredients in fragrance oils are known to be eye or skin irritants and environmentally hazardous substances. When present at certain concentrations, they trigger various health or environmental warning statements and safety pictograms. It’s your job to make sure your candle labels are showing the right information.

  • You can learn how to calculate the CLP labels yourself using the information (Safety Data Sheet) for the fragrance provided by your supplier;  it does take some time and effort to become confident in this, with thorough reading of the regulations and lots of research it can be done.  The chemicals that have to be listed on a label are the ones listed in section 3 of the SDS.
  • There are companies that provide training and software for calculating your own CLP and SDS labels, but they are quite expensive;
  • At the Soap Kitchen we provide Safety Data Sheets from our fragrance suppliers at 10% in wax, containing the information you would need to include on your CLP labels for candles or wax melts with a concentration of 10% or under. Although to be absolutely accurate, each different concentration of fragrance may require slightly different labels, because it is not a problem overstating hazardous materials, a 10% SDS will cover all hazardous materials in a candle when a fragrance is included at 10% or under. These SDS are available on each fragrance’s page on the website.
  • We also recommend contacting your local Trading Standards for guidance; they can be particularly helpful in understanding how the regulations apply to your various products.

 

General rules for the application of labels

  • Labels must be fixed to one or more surfaces of the packaging containing the substance or mixture and must be readable horizontally when the package is set down normally.
  • The hazard pictogram must stand out clearly. They must be at least 1cm square in size. They must be diamond shaped and show a black image on a white background, with a red frame.
  • The label elements shall be clearly and indelibly marked.

 

Label Elements (as referred to in Article 17(1)

  • the name, address and telephone number of the supplier
  • the nominal quantity (unless this quantity is specified elsewhere on the package)(ie the weight)
  • Product Identifiers. As a general rule, the term used for identification of the substance or mixture should be the same as that used in the safety data sheet.   For more information read sub-section (Article 18(2)) and (Article 18(3)) of the CLP REGULATION (EC) No 1272/2008.
  • hazard pictograms. A hazard pictogram is a pictorial presentation to communicate information on the hazard concerned, see also the definition provided in Articles 2(3) and 31(2) of CLP.  According to CLP Article 19, the classification of a substance or mixture determines the hazard pictograms that have to be displayed on a label.
  • signal words. A signal word indicates the relative level of severity of a particular hazard. The label must include the relevant signal word in accordance with the classification of the hazardous substance or mixture: more severe hazards require the signal word ‘Danger’ while less severe hazards require the signal word ‘Warning’. see CLP Article 20
  • where applicable, hazard statements , the appropriate precautionary statements, and a section for supplemental information (more on these later on)

 

Certain labelling exemptions apply e.g. to substances and mixtures contained in packaging that is small (typically less than 125 ml) or is otherwise difficult to label. You can find more information regarding this on page 43 here https://echa.europa.eu/documents/10162/23036412/clp_labelling_en.pdf/89628d94-573a-4024-86cc-0b4052a74d65

Here is an example label showing which elements are which:

Hazard Pictograms

You can find all 9 Hazard Pictograms with the meaning and examples of precautionary statements here https://echa.europa.eu/regulations/clp/clp-pictograms

 

 

Hazard Statements

The Hazard Statements are those that provide the consumer with a direct warning as to what the mixture may do – the nature of the hazard. If a Hazard Statement is triggered by a particular ingredient at a specific concentration, it MUST be included on the label, along with its relevant pictogram.

Some examples of Hazard Statements;

  • May cause an allergic skin reaction.
  • Harmful to aquatic life with long lasting effects.
  • Causes serious eye irritation.

Precautionary Statements

The Precautionary Statements are a set of instructions that advise the customer how to avoid or minimise the hazards that may be caused by the hazardous mixture.

Such as;

  • IF ON SKIN: Wash with plenty of soap and water.
  • Avoid release to the environment.
  • Wash hands and other contacted skin thoroughly after handling.

The inclusion of statements – ie which ones to include – seems to cause much confusion. The regulations state that ‘relevant’ precautionary statements should be included, with some being mandatory, others recommended and others advised. As with all legislation regarding the sales of products we recommend discussing this with your own local Trading Standards.

As there are hundreds of various Hazard Statements and their associated Signal Words, Precautionary Statements and Pictograms there is not enough room to list them all here. You can find more info on pages 82-191 of https://echa.europa.eu/documents/10162/23036412/clp_labelling_en.pdf/89628d94-573a-4024-86cc-0b4052a74d65

 

Candle Safety Labels

In addition to the CLP labels, candles must also have a candle safety label, compliant European Standards, particularly BS EN 15494:2007 “Product Safety Labels” which specifies the format and content of product warning labels for indoor candles. You can read more about this here http://www.britishcandles.org/documents/www.britishcandles.org/Trading_Standards/candlesadvicesheet(v5).pdf

It is a requirement that the General Warning Sign be included in all labelling. There are also four mandatory safety messages which must be included on all labels. The warning message may be given as a pictogram or as text.

 

In addition to the minimum safety information as outlined above, the standard encourages the use of optional safety information where appropriate. The optional ‘warnings’ depend on the type of candle being produced/sold, as they are not all appropriate to all types of candle.

 

 

Further Reading and Support

We strongly recommend that you read some of these articles and documents, as well as doing your own research.


Disclaimer

This article is meant as a guide. Whilst every care is taken to ensure the accuracy of the above information, we accept no responsibility for any inaccuracies. Regulations often change and we cannot guarantee that this article will be updated in accordance with any changes that may take place.


Some customers may also be interested in the services this company offers: Cosmetic Label Review Services Ltd (CLRS Ltd) are a start up consultancy business offering timely label review services in accordance with EU Regulation 1223/2009.

We are here to ensure that cosmetic businesses have compliant labelling for their cosmetic products, making them ready to notify to the Cosmetic Product Notification Portal (CPNP). We aim to greatly minimise regulatory risk for the customer whilst ensuring a fast product launch since the customer should not have to make changes to an already compliant label.

We are able to carry out label reviews in English and proofread other languages which may be present on the label (multilingual review). A standard label review would cost £100, with an additional surcharge of £50 for each country covered. Languages to be proofread will depend on the countries those products are going to be sold in. Within the review we will advise on country specific requirements as well as the key EU legislative requirements which includes any required changes relating to Brexit. We will offer a re-review free of charge should your label not meet the requirements first time. Turnaround times for all reviews are currently 3-5 working days.

 
We specialise in the regulatory review of cosmetic product labels but can also provide advice as needed around aspects of other legislation such as CLP and Product Information Files (documentation that is required legally) via clrservicesltd@gmail.com. Website in progress- for more information please email the above address- Hopefully more coming soon from CLSR.

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