Category: Advice / Law and CLP | Reading time: 11 minutes
Introduction
You've designed a beautiful label. Elegant font, logo, fragrance name – it looks professional. But is it legally compliant?
A scented candle is a chemical mixture – and as such, requires proper labeling. Even if it is not classified as hazardous, the label must include manufacturer's details, nominal quantity, and batch number. And if it is classified (which often results from sensitizing substances in the oils) – pictograms, H/P statements, and possibly UFI are added. In addition – regardless of classification – every candle needs a warning label according to standard PN-EN 15494.
In this article, we will show you, element by element, what must be on the label, how it looks in practice, and what mistakes manufacturers make most often. At the end, you will find ready-made examples of three types of labels.
1. Two labels, not one!
Before we go into detail, you need to understand one thing: your candle must have two separate sets of information – which can be placed on one physical sticker, but these are distinct legal obligations:
| CLP Label | Warning Label PN-EN 15494 | |
|---|---|---|
| When required? | Always for every candle (as a mixture). For a candle classified as hazardous or with EUH208 – additionally pictograms, H/P statements, and UFI (if applicable) | Always for every candle, even unscented ones |
| What does it contain? | Manufacturer's data, nominal quantity, batch number, product name; in case of classification additionally: GHS pictograms, signal word, H/P statements, UFI (if necessary) | Yellow triangle, safety messages for use |
| Legal basis | CLP Regulation (EC) 1272/2008 | Standard PN-EN 15494:2020-04 |
| Applies to what? | Chemical hazards and instructions on how to manage them (allergy, environment) | Physical hazards (fire, burn) |
Many people confuse these two labels or think that one replaces the other. It doesn't. You need both – although you can physically place them on one sticker.
2. CLP Label - mandatory elements
If your candle is classified as hazardous (e.g., H317) or requires the EUH208 statement, the CLP label must contain the following elements:
Product identifier
The name of your candle – e.g., "Soy Candle Pure Cotton". It must be identical to the name in the Safety Data Sheet. If your SDS says "Soy Candle – Pure Cotton", and your label says "Candle Pure Cotton" – that's a non-compliance.
Hazard pictograms (GHS)
Red diamonds with symbols. Most common for candles:
- GHS07 (exclamation mark) – skin sensitization (H317), irritation
- GHS08 (health hazard) – rarer, but possible with some substances
- GHS09 (environment) – aquatic toxicity (H410, H411)
Minimum pictogram size: 1 cm × 1 cm (measured along the side of the diamond).
Signal word
Two possibilities:
- "Danger" – for more serious hazards (rare in candles)
- "Warning" – for lesser hazards (most common in candles – sensitization H317)
If the candle is not classified as hazardous (only has EUH208) – a signal word is not required. The label then does not contain a signal word.
Hazard statements (H statements)
Describe specific hazards. Most common in candles:
- H317 – May cause an allergic skin reaction
- H411 – Toxic to aquatic life with long lasting effects
- H412 – Harmful to aquatic life with long lasting effects
Precautionary statements (P statements)
Instructions for safe handling. Examples for candles:
- P261 – Avoid breathing mist or vapours
- P272 – Contaminated work clothing should not be allowed out of the workplace
- P273 – Avoid release to the environment
- P280 – Wear protective gloves
- P333+P313 – If skin irritation or rash occurs: Get medical advice/attention
Important: Some P statements (e.g., "Keep out of reach of children") may be required even for candles not classified as hazardous. P statements are not just an addition to pictograms – they are also basic instructions for safe use.
Supplemental information (EUH)
Most common for candles:
- EUH208 – "Contains: [name of substance]. May produce an allergic reaction."
EUH208 appears when a single sensitizing substance is in concentration:
- 0.1–1% in the candle – for Skin Sens. Cat. 1 or 1B substances
- 0.01–0.1% in the candle – for Skin Sens. Cat. 1A substances
EUH208 does not require a pictogram or UFI.
Substances to be listed
If the mixture is classified as H317, you must list on the label the ingredients that determine the classification. Most often, these are allergens such as: linalool, limonene, citral, eugenol, coumarin, cinnamal. The list comes from section 2.2 of the Safety Data Sheet.
UFI code
16-character code (e.g., UFI: E4GV-R56A-QJ3V-C2F6). Required only when the candle is classified as hazardous due to health or physical hazards (H317 and others). For EUH208 alone or environmental classification alone – it is not required.
Details of the responsible person
Company name, address, phone number, email address of the manufacturer or the person placing the product on the market. You – as the candle manufacturer – are the responsible person, not the oil manufacturer.
Nominal quantity
Net mass or volume of the product (e.g., "~220g Net").
Batch number
Mandatory traceability element (e.g., "BN:0001"). Also required by GPSR.
3. Warning label according to PN-EN 15494
This label concerns the safe use of the candle – fire, burns, decorations. It is required for every candle, even unscented, even if not classified as hazardous.
Mandatory elements (minimum):
- General warning sign – yellow triangle with an exclamation mark
-
Minimum 3 safety messages, e.g.:
- Never leave a burning candle unattended
- Keep away from flammable materials
- Keep out of reach of children and pets
Optional messages (recommended for specific types of candles):
- Trim wick to 5 mm before each lighting (container candles)
- Burn on a heat-resistant surface (pillar candles)
- Do not burn candle for less than X minutes and longer than Y hours
- Do not move a burning candle
- Do not use water to extinguish (gel candles)
Messages can be conveyed as pictograms (icons) or as text in the language of the country of sale. PN-EN 15494 pictograms are standard icons – you don't invent your own.
4. Where to place the label – attachment rules
The CLP Regulation clearly defines how the label must be affixed:
- Permanently affixed to the packaging – not a loose insert, not a leaflet in a box
- Legible horizontally when the packaging is in its normal upright position On the packaging, NOT on the wax – wax is a mixture, not packaging. The CLP label goes on the jar, box, or band
- On the inner AND outer packaging – if the candle is in a jar in a box, the label must be on both
Alternative solutions for difficult shapes:
- Hang tag tied to the candle
- Paper band around a pillar candle
- Fold-out label – allowed by CLP amendment 2024/2865
- Label on outer packaging if inner packaging is too small
Practical tip: The most common mistake is to stick the CLP label directly on the wax of a pillar candle. Wax is not packaging – you need a band, hang tag, or box.
5. Label formatting requirements (CLP amendment 2024/2865)
The CLP amendment from 2024 introduced detailed requirements for label legibility. Most of them come into force on January 1, 2028 (deferred by regulation 2025/2439), but it is worth knowing and applying them now:
- Sans-serif font (e.g., Arial, Helvetica, Calibri – not Times New Roman)
- Black text on a white background
- Line spacing minimum 120% of font size
- Minimum font size:
- Packaging < 0.5 liters: minimum 1.2 mm (x-height)
- Packaging 0.5–3 liters: minimum 1.4 mm
- Minimum label dimensions for packaging < 3L: 52 × 74 mm (if possible)
Practical tip: Although the deadline is 2028, if you are designing new labels now – apply these requirements immediately. You will avoid rework in two years.
6. Three label examples - from simplest to full
Example A: Candle WITHOUT classification (e.g., Chocolate & Cocoa Bean at 6%)
The candle does not exceed any classification thresholds. The label needs:
- ✅ Product name
- ✅ Manufacturer's details (name, address, phone, email)
- ✅ Batch number
- ✅ Net weight
- ✅ Selected P statements (e.g., "Keep out of reach of children") – even without classification
- ✅ Warning label PN-EN 15494 (yellow triangle + 3 messages)
- ❌ No CLP pictograms
- ❌ No H statements
- ❌ No UFI
The simplest option. Minimum formalities.
Example B: Candle with EUH208 (e.g., oil with low threshold at 8%)
The sensitizing substance exceeds 0.1% but not 1%. You add to the label:
- ✅ Everything from Example A, plus:
- ✅ EUH208 statement: "Contains: linalool. May produce an allergic reaction."
- ❌ Still no CLP pictograms
- ❌ Still no UFI and PCN
Additional information on the label, but without pictograms and without additional costs.
Example C: Candle with H317 + H411 (e.g., Calamansi & Coriander at 10%)
Full classification – sensitizing + environmental. On the label:
- ✅ Everything from Examples A and B, plus:
- ✅ GHS07 (exclamation mark) + GHS09 (environment) pictograms
- ✅ Signal word: "WARNING"
- ✅ H statements: H317, H411
- ✅ P statements: P261, P273, P280, P333+P313, P362+P364, P391
- ✅ List of substances determining classification
- ✅ UFI code: UFI:XXXX-XXXX-XXXX-XXXX
- ✅ PCN notification to ECHA (before sale)
Full set. More work, but the candle is fully legal for sale.
7. How to do it in practice - our CLP Label Generator
Manually creating a CLP label is tedious – you have to check which pictograms, which H and P statements, which substances to list, and in what format. That's why we created a CLP Label Generator available to TopWosk customers.
How it works:
- You select a fragrance from our database
- You select concentration (6/8/10%), mass, company details
- The generator automatically selects pictograms, H/P statements, and substances to be listed
- You get a preview of the ready label with PN-EN 15494 pictograms
- Export for printing
👉 Try the CLP Label Generator →
8. Common mistakes on candle labels
Missing PN-EN 15494 warning label – even if the candle is not chemically "hazardous," a warning label (yellow triangle) is mandatory for EVERY candle.
CLP label on wax instead of packaging – wax is a mixture, not packaging. The label must be on the jar, box, or band.
Inconsistency between the name on the label and in the SDS – the product name must be identical in both documents.
Too small pictograms – the minimum is 1 cm × 1 cm. On small packaging, this is a challenge, but you cannot go smaller (unless the packaging is ≤ 125 ml – then minimum 10 × 10 mm).
Missing batch number – required by both CLP and GPSR. Without it, you lack product traceability.
Label only on the outer packaging – if the candle in a jar is in a box, the CLP label must be on both: on the jar (inner packaging) and on the box (outer packaging).
"My candle is not hazardous, so I don't need a CLP label" – No! Even a candle not classified as hazardous requires basic information from CLP: manufacturer's details, nominal quantity, batch number, and product name. The CLP label is not only required for classification – it is required for every mixture placed on the market.
Summary
A candle label is not just a matter of aesthetics – it is a legal obligation. You need two types of labeling: a CLP label (for chemical hazards and basic data) and a PN-EN 15494 warning label (for safe use).
Key principles:
- Warning label (yellow triangle + 3 messages) is mandatory for EVERY candle
- CLP label (with basic data) is mandatory for every candle as a mixture – and for classification, pictograms, H/P statements, and possibly UFI are added
- The label must be on the packaging, not on the wax
- Name on the label = name in the Safety Data Sheet
In the next article, we will explain the key difference between EUH208 and H317 – and why this seemingly minor difference determines how much money and time you will spend on formalities.
At TopWosk, we provide ready-made Safety Data Sheets with the data needed to create a correct CLP label. And our CLP Label Generator will do the rest for you – choose a fragrance, enter your data, and you have a ready-to-print label. Check out our fragrance oils →