GPSR 2024 - a new obligation no one in the candle industry is talking about

Category: Advice / Law and CLP | Reading time: 9 minutes

Introduction

You talk to candle makers about regulations – you hear REACH, CLP, safety data sheets. But ask about GPSR and you'll get a blank stare. "What's that?" – is the most common reaction.

Meanwhile, GPSR has been in force since December 13, 2024. It applies to anyone selling consumer products in the EU – including candles. And online marketplaces (Allegro, Amazon, Etsy) have already started enforcing compliance.

This article is the first comprehensive guide to GPSR in the Polish candle industry. We will explain what this regulation is, what you need to do as a candle manufacturer, and how to prepare for it – step by step.

1. What is GPSR?

Regulation (EU) 2023/988 – the General Product Safety Regulation – is a new EU regulation on general product safety. It replaced the old Directive 2001/95/EC, which had been in force for over 20 years.

In simple terms: GPSR states that every consumer product placed on the EU market must be safe. Sounds trivial? The difference compared to the old directive is that GPSR is much more specific – it requires documenting that your product is safe, not just declaring it.

Who does it concern?

• Manufacturers – if you make candles and sell them, then you
• Importers – if you import candles from outside the EU
• Distributors – if you resell other people's candles
• Marketplace platforms – Allegro, Amazon, Etsy (that's why they require documentation)

The scale of operation does not matter. Do you make 50 candles a month at home? GPSR applies to you just as much as it does to a factory producing 50,000 units.

2. GPSR vs CLP - they are not the same!

The most common misconception: "I have CLP classification, so I comply with GPSR." No. These are two separate legal systems that complement each other but do not replace each other.

A candle can be "chemically safe" (no CLP classification) but "physically unsafe" (unstable, too high a flame, no instructions for use). CLP does not check this – GPSR does.

Key: You need BOTH compliances. CLP without GPSR = incomplete. GPSR without CLP = incomplete.

3. Five obligations of a candle manufacturer under GPSR

Obligation 1: Product risk analysis

You must conduct and document a risk assessment for your candle. Not in your head - on paper (or in a file). The analysis should include:

• Fire risk - is the candle stable? Is the flame not too high? Is there no contact with flammable materials?
• Chemical risk - are the substances in the oil correctly classified and labeled? (this is where CLP comes in)
• Burn risk - does the wax spill? Does the container not overheat excessively?
• Risk to children - does the candle not look like a toy or food? (colorful candles in the shape of cookies!)
• Risk of foreseeable misuse - e.g., burning a candle on a plastic surface, falling asleep with a burning candle

The analysis does not have to be a 50-page report. For a simple soy candle in a jar, it can be 2-3 pages identifying hazards and describing preventive measures (warning label, usage instructions, safety tests).

Obligation 2: Technical documentation

You must maintain technical documentation for the product, which includes:

• General product description (name, type of wax, oil, capacity, wick type)
• Chemical composition (Safety Data Sheet for oil and wax)
• CLP classification with report
• Label design (CLP + PN-EN 15494)
• Safety test results (flame stability, soot emission)
• Risk analysis (see above)
• Product photos with labels

The documentation must be stored for 10 years from the date the product was last placed on the market and made available to supervisory authorities upon request.

Obligation 3: Responsible person in the EU

Every consumer product on the EU market must have a designated responsible person based in the EU. If you produce candles in Poland – that's simply you (or your company). The responsible person's data must be on the product.

A problem arises when you import – e.g., you buy wax from Asia or finished candles from China. In that case, you must designate a responsible person in the EU (this can be you as the importer, or a specialized company).

Obligation 4: Product labeling

On the product (or packaging, if not possible on the product), the following must be included:

• Product name or identifier allowing recognition
• Name and address of the manufacturer (or responsible person)
• Electronic address - email or website (this is new compared to the old directive!)
• Batch number or other traceability element
• Warnings - in the language of the country of sale

Most of this overlaps with what you should already have on your CLP and PN-EN 15494 labels. But the electronic address is a new requirement that many manufacturers overlook.

Obligation 5: Traceability and corrective actions

You must enable product tracking – know which batch went to which customer. A batch number on the label is the minimum. And if your product turns out to be unsafe, you must:

• Immediately notify supervisory authorities (UOKiK)
• Withdraw the product from the market
• Inform customers

It sounds serious, but in practice, it means having a system: batch number → customer list → possibility of contact.

4. What platforms already require

Marketplace platforms are obliged by GPSR to verify that products sold on them meet the requirements. In practice:

• Allegro - requires the data of the responsible person in the EU, requests documentation on demand, blocks offers without required information
• Amazon - requires GPSR compliance number, technical sheet, manufacturer data. Lack of these = offer blocked
• Etsy - introduces requirements for sellers from the EU, requires manufacturer data and warnings

The trend is clear: platforms will demand more and more. It's better to prepare now than to lose sales due to blocked listings.

5. How to prepare - practical plan

Step 1: Organize labeling (1 day)

Check if every candle has: product name, manufacturer's data with electronic address (email!), batch number. If anything is missing - add it at the next label print.

Step 2: Conduct risk analysis (1-2 days)

Take an A4 sheet (or template) and list: hazards of your candle → how you prevent them → what measures you apply. For a typical soy candle in a jar, this is not complicated - but it must be recorded.

Step 3: Compile technical documentation (1 day)

Gather in one place (physical or digital folder): SDS for the oil, SDS for the wax, CLP classification of the candle, label design, test results, risk analysis. Mark with date and version number.

Step 4: Implement a batch system (ongoing)

Each batch of candles should have a unique number (e.g., BN:2025-04-001). On the label and in your records. So that you know what, when, and for whom you made it.

Step 5: Update platform data (1 hour)

Go to Allegro/Etsy/Amazon and check if your listings have all the required fields: manufacturer data, email address, warnings. Fill in any gaps before the platform does it for you (by blocking the offer).

6. Frequently asked questions about GPSR

"Does GPSR apply to unscented candles?" - Yes. GPSR applies to ALL consumer products, regardless of whether they are chemically classified. An unscented candle can still tip over, burn too high, or overheat its container.

"I have a sole proprietorship - do I need technical documentation?" - Yes. Scale does not matter. But the documentation does not have to be overly extensive - a few pages are enough for a simple product.

"I only sell at fairs / markets - does it concern me?" - Yes. GPSR covers any "making available on the market" - fairs, markets, direct sales. The only exception is products made exclusively for personal use.

"What are the penalties for non-compliance?" - Penalties for violating GPSR are the responsibility of the national authority (in Poland: UOKiK). These may include: an order to withdraw the product, a financial penalty, a sales ban. Platforms may block your offers regardless of the authority.

"Does CLP replace GPSR risk analysis?" - No. CLP concerns chemical hazards. GPSR risk analysis covers ALL hazards - chemical, physical, mechanical, fire. CLP can be part of GPSR documentation (section on chemical hazards), but it does not replace it.

Summary

GPSR is not another scare tactic - it's an organization of obligations that a good manufacturer should already meet. Your candle must be safe, documented, and traceable. Sales platforms are enforcing this and will enforce it more strictly.

Five obligations to remember:

1. Risk analysis - documented, not in your head
2. Technical documentation - everything in one folder, 10 years of storage
3. Responsible person - based in the EU, data on the product
4. Labeling - name, manufacturer data, email, batch number
5. Traceability - batch system, readiness for withdrawal

At TopWosk, we help you with the chemical part of GPSR documentation – we provide ready-made SDS and CLP classifications for every oil. This is one element of your technical documentation. The rest (risk analysis, physical tests, batch system) you have to do yourself – but at least the chemical paperwork is taken care of. Check out our fragrance oils with documentation →