Category: Advice / Law & CLP | Reading time: 9 minutes
Introduction
EUH208 and H317. Two codes that look similar – but there's a gulf of costs, formalities, and time between them. And yet, most CLP guides treat them as if they were the same. They are not.
If you make scented candles and want to sell them legally, understanding this difference is absolutely crucial. Because this is where the decision is made: does your candle only require one line of text on the label – or full CLP labelling with pictograms, a UFI code, and notification to poison control centers across Europe.
In this article, we will explain this difference once and for all, show how much it costs to cross the threshold, and how to choose the right fragrance oil concentration to stay on the safe side.
1. EUH208 - information, not classification
Let's start with EUH208, as it's simpler. EUH208 is an supplementary information statement – it is not a hazard classification. It appears on the label when your candle contains a single sensitizing substance at a concentration of:
- 0.1–1% in the candle – for substances classified as Skin Sens. 1 or 1B
- 0.01–0.1% in the candle – for substances classified as Skin Sens. 1A (stronger allergens, lower threshold)
Above these values (1% for 1/1B, 0.1% for 1A), H317 classification begins – with full consequences.
On the label, it looks like this:
Contains: linalool. May produce an allergic reaction.
And that's it. One line of text. No pictograms, no red diamonds, no "WARNING" signal word.
What you need to do when you have EUH208:
- ✅ Add the EUH208 statement to the label (with the name of the substance)
- ✅ Have a Safety Data Sheet (if you sell B2B)
- ❌ You do NOT need GHS pictograms
- ❌ You do NOT need a signal word
- ❌ You do NOT need a UFI code
- ❌ You do NOT need a PCN notification
2. H317 - full classification with all consequences
H317 is a completely different league. It is a hazard statement – "May cause an allergic skin reaction". It appears when a single sensitizing substance in your candle exceeds 1% (for Skin Sens. 1/1B) or 0.1% (for Skin Sens. 1A).
A candle with H317 is officially classified as a hazardous mixture. And this triggers an avalanche of obligations:
What you need to do when you have H317:
- ✅ GHS07 pictogram (exclamation mark in a red diamond) on the label
- ✅ Signal word "WARNING"
- ✅ H (H317) and P (P261, P272, P280, P302+P352, P333+P313, P362+P364, P501) statements
- ✅ List of substances determining the classification
- ✅ UFI code – generated and placed on the label
- ✅ PCN notification to ECHA – separately for each EU country where you sell
- ✅ Safety Data Sheet (also mandatory for B2C sales if the customer requests it)
3. Cost comparison - this is the crux
Here's a concrete comparison of how much each scenario costs you as a candle manufacturer:
| No classification | Only EUH208 | H317 (+ possibly others) | |
|---|---|---|---|
| Pictograms on the label | None | None | Yes (GHS07, possibly GHS09) |
| UFI code | No | No | Yes |
| PCN notification | No | No | Yes (per country!) |
| Cost of PCN (self-performed) | - | - | Free, but requires learning the ECHA system |
| Cost of PCN (via chemist) | - | - | 300-600 PLN per fragrance per country |
| Cost of PCN (via TopWosk + Chemtra) | - | - | 125 PLN per fragrance (Poland) |
| Label complexity | Minimal | +1 line of text | Full CLP label |
| Preparation time | 5 minutes | 10 minutes | 1-3 days (with PCN) |
| Update on recipe change | None | Text change on the label | New UFI + new PCN notification |
Do you see the scale? Moving from EUH208 to H317 is not "adding a pictogram" – it's triggering a whole administrative process that costs money and time for EVERY fragrance, EVERY recipe change, and EVERY new country of sale.
4. How this translates to your concentrations
A practical example. You have a fragrance oil in which a single sensitizing substance (cat. 1B) constitutes 20% of the oil's composition. At different oil concentrations in the wax, you get:
| Fragrance oil concentration in wax | That substance in the candle | Result |
|---|---|---|
| 4% | 0.8% | EUH208 (below 1%) |
| 5% | 1.0% | H317 (threshold reached!) |
| 6% | 1.2% | H317 |
| 8% | 1.6% | H317 |
| 10% | 2.0% | H317 |
The difference between 4% and 5% fragrance oil is the difference between "one line on the label" and "full UFI + PCN procedure for several hundred zlotys". One percentage point.
But beware – the threshold is not just about sensitization!
This is a mistake most guides make. They only look at the H317 threshold and say: "below 5% you are safe." But the actual classification threshold is the lowest threshold among ALL hazard classes – not just sensitization.
A concrete example from our practice: a fragrance oil whose H317 threshold was 2.28% (sensitization) also had an Aquatic Chronic 3 (H412) threshold of 1.75%. Someone who only looked at sensitization and used 2% oil thought they were "clear" – but from 1.75%, they already had an obligation for environmental labelling.
That's why at TopWosk, we provide one classification threshold for each fragrance oil – the lowest of all hazard classes. You don't have to check sensitization, environment, and irritation separately. You look at one number and you know.
5. Why this is important when choosing an oil
Not all fragrance oils are created equal. Here's how a comparison of two fragrances from our offer might look:
| Fragrance Oil A (e.g., chocolate) | Fragrance Oil B (e.g., citrus-spicy-herbal) | |
|---|---|---|
| Classification threshold | ~10% | ~1.75% |
| At 6% | No classification | H317 + H412 + UFI + PCN |
| At 8% | EUH208 (possibly) | H317 + H412 + UFI + PCN |
| At 10% | EUH208 | H317 + H412 + UFI + PCN |
| Cost of formalities at 6% | 0 PLN | 100-600 PLN |
The same percentage of oil, the same wax, the same production process – but completely different legal and cost consequences. Choosing a fragrance is not just about what smells nice – it's also a business decision.
6. Concentration selection strategy - how to do it smartly
Here's how experienced manufacturers approach it:
Strategy 1: "Always below the threshold"
You choose the fragrance oil concentration so that it is always below the classification threshold. For oils with a high threshold (e.g., 10%+), you can safely use 6-8%. For oils with a low threshold (e.g., 2%), you must stay at 1.5%. Advantage: zero additional formalities. Disadvantage: some candles will be less intensely scented.
Strategy 2: "EUH208 zone"
You aim for a concentration that results in EUH208 but not H317 – meaning the sensitizing substance is above 0.1% but below 1% in the candle. You have the information on the label, but without pictograms and without UFI/PCN. This is the "golden mean" for many manufacturers.
Strategy 3: "Full power with documentation"
You want a stronger candle and accept the costs of H317 – pictograms, UFI, PCN. This is okay! A candle with H317 is fully legal. But you need to know how much it costs and plan for it. With ready documentation from TopWosk, the PCN cost is 125 PLN (through our partner – Chemtra) instead of 300-600 PLN from an external chemist.
Practical tip: There is no single "right" strategy. It depends on your business model, the number of fragrances, and your target market. But to choose consciously, you need to know the thresholds of your oils. At TopWosk, we provide them for each product.
7. Common myths
"EUH208 is the same as H317, just a milder version" – No. EUH208 is supplementary information, not a hazard classification. H317 is a classification. It's like the difference between a "health warning on coffee" and a "prescription for medicine." A completely different legal category.
"If I have EUH208, I must have a UFI" – No. A UFI is only required for classification as a hazardous mixture due to health/physical hazards. EUH208 in itself is not such a classification.
"If I lower the concentration below the H317 threshold, I can ignore EUH208" – Not quite. If a single sensitizing substance is above 0.1% in the candle, EUH208 is still required. The EUH208 threshold (0.1% per substance) is lower than the H317 threshold (1% per substance).
"6% oil is always safe" – There is no universal safe concentration. An oil with a 30% threshold is safe even at 12%. An oil with a 1.5% threshold requires full classification at just 2%. Each oil has its own threshold.
Summary
The difference between EUH208 and H317 is not a nuance – it's a decision that affects the cost, time, and complexity of selling each of your candles. EUH208 = one line of text. H317 = pictograms + UFI + PCN + hundreds of zlotys in formalities.
Three things to remember:
- EUH208 ≠ H317 – these are fundamentally different legal categories with different consequences
- Classification threshold = lowest threshold of ALL classes – don't just look at sensitization, check environment and other health hazards too
- Conscious concentration selection = real savings – a difference of 1 percentage point can mean several hundred zlotys less in formalities
At TopWosk, we provide the classification threshold for each fragrance oil – the lowest of all hazard classes. You also get ready-made Safety Data Sheets in three concentrations (6%, 8%, 10%) so you can choose consciously. And if your candle requires a PCN, we cooperate with Chemtra – the notification costs 125 PLN (instead of 300-600 PLN from an external chemist). Condition: the SDS must be from TopWosk. Check out our fragrance oils →