CLP Classification of a Candle Step-by-Step - What is it and How to Do it?

Category: Advice / Law and CLP | Reading time: 10 minutes

Introduction

CLP classification. Sounds like something from a laboratory, right? In reality, it's the answer to the question: does your candle pose a hazard – for example, can it cause an allergic reaction, skin irritation, or harm the environment? And if so, to what extent?

Every scented candle is a chemical mixture (wax + fragrance oil). Before you sell, distribute, or import it, you must formally answer this question – and the answer will be given by the CLP classification result. This is not an option. It is a legal obligation arising from Regulation (EC) No 1272/2008, regardless of whether you produce 10 candles a month or 10,000.

In this article, we will explain step by step: what CLP classification is, what you need to do it, what the possible results are, and how much it costs.

1. What is CLP classification – in simple terms

CLP classification is a process in which you analyze the composition of your candle and check whether the substances it contains (mainly from the fragrance oil) exceed thresholds at which the mixture is considered "hazardous".

Think of it as risk management. CLP classification allows you to assess the risk – e.g., the product may cause skin sensitization – and at the same time gives you guidelines on how to deal with that risk: if you have come into contact with the product, wash your hands with soap and water.

CLP stands for Classification, Labelling and Packaging. The regulation specifies:

• Classification – determining the hazard posed by a substance or mixture
• Labelling – what must appear on the label (pictograms, H and P statements)
• Packaging – how the product must be packaged

2. When MUST you do a classification?

Short answer: before placing it on the market. And "placing on the market" is not just selling – it also includes:

• Selling to customers (online, at fairs, in stores)
• Selling to stores, florists, hotels (B2B)
• Giving away samples (yes, even free ones!)
• Importing from abroad

If you make candles only for yourself and never give them to anyone – you don't need to classify. In any other case – you must.

Important: Classification applies to each mixture (candle). If you have 20 scents – you need 20 classifications. Each fragrance composition has a different chemical composition, so each candle will have a different classification.

3. What do you need for classification?

Before you start, collect these documents from your suppliers:

Mandatory:

• Safety Data Sheet (SDS) for the wax – confirms that the wax is not classified as hazardous (it usually isn't)
• Safety Data Sheet (SDS) for the fragrance composition – this is a key document. Section 3 contains the composition of individual ingredients of the composition, along with a description of their hazards and their concentrations
• IFRA Certificate – provides information on maximum safe concentrations of fragrance oil in various products (candles = category 12)

Optional, but valuable:

• List of allergens in the oil – contains exact concentrations of sensitizing substances (instead of ranges from the SDS). Allows for calculation of a higher (more favorable) classification threshold. Necessary when using a fragrance composition in cosmetic products

Practical tip: If your supplier doesn't provide you with a Safety Data Sheet for the fragrance oil – change suppliers. This is not an optional document. Without it, you cannot perform classification and cannot legally sell candles.

4. How the process works – 3 scenarios

Scenario A: You buy from a supplier with ready classifications

At TopWosk, we provide ready-made CLP classifications and Safety Data Sheets for candles at three concentrations (6%, 8%, 10%) for each fragrance composition. You buy the fragrance oil, download the ready file, fill in your company details – done.

Scenario B: You do the classification yourself

If you have knowledge of CLP and understand the calculation methodology (limit concentrations, thresholds, M-factors), you can perform the classification yourself. You need:

• SDS of the fragrance composition (section 3 - composition)
• Knowledge of limit concentrations for hazards from Annex I of CLP
• Calculation tools (pencil, paper, calculator)

Scenario C: You outsource to a chemist

You send the SDS of the fragrance oil and wax to a company specializing in chemical documentation. The chemist performs the classification, prepares a report, and optionally a Safety Data Sheet for the candle.

5. What happens "under the hood" – the calculation method

You don't have to do this yourself, but it's good to understand the logic. Here's what classification looks like in simplified terms:

Step 1: Extract the composition from section 3 of the fragrance oil SDS

There you will find a table of hazardous substances with their concentrations (in ranges, e.g., "≥1 - <5%") and classifications (e.g., Skin Sens. 1B; H317).

Step 2: Convert to the final mixture

If the fragrance oil contains 5% of a sensitizing substance, and you use 8% of the fragrance oil in the wax, then your candle contains: 5% × 8% = 0.4% of that substance.

Important: For skin sensitization (H317), each sensitizing substance is assessed separately – they are not summed. You check whether any single sensitizing substance exceeds the threshold. This is a common mistake – many guides state that they are summed. They are not.

Step 3: Compare with CLP thresholds

For skin sensitization (the most common problem in candles) – you check each substance separately:

• Substance with H317 cat. 1 or 1B < 0.1% in the candle (or H317 cat. 1A < 0.01%) → the candle does not pose a hazard due to this substance
• Substance with H317 cat. 1 or 1B ≥ 0.1% in the candle (or H317 cat. 1A ≥ 0.01%) → EUH208 statement on the label – list all substances in this range, without a pictogram
• Substance with H317 cat. 1 or 1B ≥ 1% in the candle (or H317 cat. 1A ≥ 0.1%) → H317 classification – exclamation mark pictogram, WARNING signal word, mandatory UFI code and PCN submission

Step 4: Check other hazard classes

Full classification involves calculating hazard thresholds for all possible hazards listed as hazards assigned to individual components of the fragrance composition in section 3 of the Safety Data Sheet. These are not limited to sensitization – they also include: environmental hazards (Aquatic Chronic/Acute), skin irritation (H315), eye irritation (H319), acute toxicity. Each class has its own thresholds.

Key principle: Your actual classification threshold is the lowest threshold among all hazard classes – not just sensitization. Sometimes, it is precisely the environmental classification that is limiting, not allergy.

6. Most common results of scented candle classification

From our experience, the results of scented candle classifications usually fall into four categories:

No classification (green light)

The candle does not exceed limit concentrations. No pictograms, no H statements, no UFI. Minimum formalities – you need a warning label according to PN-EN 15494 (mandatory for every candle). Remember, however, that a CLP label with basic information (manufacturer's data, net content) is always required.

Only EUH208 (yellow light)

The candle contains a sensitizing substance above 0.1%, but no single substance exceeds the 1% concentration, which is the limit concentration for H317 hazard. The label states: "Contains: [substance name]. May produce an allergic reaction." But – no pictogram, no UFI, no PCN. This is the zone you want to be in.

H317 - sensitizing (orange light)

If a single substance classified as H317 cat. 1 or 1B exceeds 1% in the candle, then the mixture will be classified as hazardous. On the label: exclamation mark pictogram, WARNING signal word, H317 and P statements. Mandatory UFI code and submission to a poison control center (PCN). Additional costs and formalities, but the candle is still legal for sale.

H412 - environmentally toxic

Some fragrance oils contain substances toxic to the aquatic environment. At higher concentrations, Aquatic Chronic 3 (H412) classification may appear – a statement on the label, but without a pictogram and without UFI (because it's solely an environmental classification). It's worth remembering this, because sometimes this threshold is lower than the sensitization threshold.

7. How much does it cost – comparison of paths

8. Common mistakes in classification

"I have one classification for a vanilla candle and I use it for all scents" - No! Each fragrance oil has a different composition. A vanilla candle might be clean, while a cinnamon one requires a pictogram. One classification per fragrance variant.

"Wax is safe, so the candle is too" - Wax itself is not hazardous. But the fragrance oil you add contains classified substances. They determine the candle's classification.

"I sum all sensitizing substances and compare with the 1% threshold" - No! For skin sensitization (H317), you assess each substance separately. You check whether any single substance exceeds the threshold - you don't sum them. This is a common mistake that leads to an overstated classification.

"I saw that 6% is safe - I can use 6% of any fragrance oil" - The threshold is individual for each fragrance oil. One oil has a threshold of 30%, another 0.25%. There is no universal "safe concentration". At TopWosk, we provide thresholds for each oil so you don't have to guess.

"Colorant does not change classification" - Usually not, but check section 2 of the colorant SDS. If it states "Mixture not classified as hazardous" - it's OK. If it is classified - you must recalculate.

"I sell on Allegro, I don't need classification" - Allegro is not a lawless zone. The classification obligation applies to anyone who places a mixture on the market - regardless of the sales channel. Moreover, Allegro increasingly demands documentation from sellers.

Summary

CLP classification is the foundation for legal sale of scented candles. It sounds complicated, but it boils down to: take the composition of the fragrance oil, calculate the concentrations in the finished candle, compare with the thresholds. The result tells you what must appear on the label and what additional obligations you have.

Three things to remember:

1. Each fragrance = separate classification (because each fragrance oil has a different composition)
2. Classification threshold = the lowest concentration at which a substance affects human health, has specific physical properties, or harms the environment (not just sensitization - sometimes the environment is limiting!)
3. No classification means no legal sale - regardless of scale

In the next article, we will show you what a correct CLP label on a candle looks like - element by element, with ready-made examples.

Don't want to deal with this? At TopWosk, for every fragrance oil, you get a ready-made classification at three concentrations (6%, 8%, 10%). Download it, fill in your company details - and you're all set. Check out our fragrance oils →