Category: Business | Reading time: 8 minutes
Introduction
You take beautiful pictures of your candles, write catchy descriptions, and post them on Instagram and Allegro. Sales are growing. And then you learn that from 2028, photos and descriptions of hazardous products online must include CLP pictograms. Yes – those red diamond shapes with an exclamation mark that you know from labels must also appear in your online store.
Does it sound absurd? Maybe a little. But it is real EU law that comes into force in less than two years. This article will explain what is changing, what you need to do, and – more importantly – what you DON'T need to do if your candle is not classified as hazardous.
1. What has changed - CLP amendment 2024/2865
In November 2024, the European Union published Regulation (EU) 2024/2865 – a comprehensive amendment to the CLP Regulation (1272/2008). Among many changes, there was a new provision regarding advertising and online sales of hazardous products.
Key fragment: if you advertise or offer for sale a mixture classified as hazardous in a way that does not allow the customer to see the label (i.e., online) – you must include information from the CLP label in the offer.
What does this mean in practice?
If your scented candle is classified as hazardous (has GHS pictograms, H/P statements, warning signal word) – in the online offer description, you must include:
- Hazard pictograms (GHS07, GHS08, GHS09, etc.) – as images
- Signal word ("WARNING" or "DANGER")
- Hazard statements (H317, H411, etc. – full texts)
- Supplemental information (EUH208, if applicable)
When does this come into force?
Originally, the new requirements were to apply from 2026. However, Regulation (EU) 2025/2439 postponed the deadline to January 1, 2028. You have time to prepare – but there's no point in waiting until the last minute.
2. Who it concerns – and who it DOES NOT
This is the most important section of this article. Many candle makers panic unnecessarily.
It CONCERNS you if:
- Your candle is classified as hazardous – it has GHS pictograms (e.g., GHS07 exclamation mark), the signal word "WARNING", H317, H411 statements, etc.
- You sell it online – online store, Allegro, OLX, Vinted, Etsy, Amazon, Instagram with a link to purchase
It DOES NOT concern you if:
- Your candle is not classified as hazardous – you stay below the classification threshold, no pictograms
- Your candle has only EUH208 – supplemental information, but no pictograms and no signal word. EUH208 itself does not require pictograms in online advertising (although it's good to include it in the description for transparency)
- You sell only stationary (market, boutique, fair) – the customer sees the label on the product
Key: If you choose the fragrance oil concentration below the classification threshold – your candle is not "hazardous" in the CLP sense, and these new requirements do not apply to you at all. Another reason to know the thresholds of your fragrance oils.
3. How it looks in practice – examples
Example A: Candle below threshold (6% fragrance oil with 10% threshold)
Classification: none or EUH208. Online offer: normal description, beautiful photos, zero pictograms in the description. Nothing changes.
Example B: Candle with H317 + GHS07 (10% fragrance oil with 5% threshold)
Classification: H317 (sensitizing), GHS07 (exclamation mark), signal word "WARNING". Online offer from 2028: in the product description, you must include an image of the GHS07 pictogram, the text "WARNING", the statement "H317: May cause an allergic skin reaction", and appropriate P statements.
How it might look in the offer description:
The product description looks normal – beautiful photos, fragrance description, capacity, burning time. And at the end (or in a dedicated "Safety" section), a block appears:
⬥ WARNING
H317: May cause an allergic skin reaction.
P261: Avoid breathing vapours.
P280: Wear protective gloves.
Contains: linalool, limonene.
[GHS07 pictogram]
This isn't an ideal marketing look – but it's legal. And it can be designed beautifully.
4. How to prepare – practical steps
Step 1: Check which candles are classified
Review your offer. Which fragrances at what concentration have pictograms? If you have ready-made SDS from TopWosk – check section 2 of each sheet. Fragrances below the threshold = zero changes. Fragrances above the threshold = you need to prepare a CLP block for the description.
Step 2: Prepare pictogram graphics
GHS pictograms must be in image format (not text, not emoji). Prepare PNG files of the pictograms you use (GHS07, GHS09, etc.) in a size of approx. 100×100px. You can download them from the ECHA website or use our CLP Label Generator, which includes them.
Step 3: Prepare a CLP block template
Create an HTML (or text) template with the pictogram, signal word, H/P statements, and a list of substances. One template per classification – if you have 5 candles with the same profile (H317 + GHS07), you need one template.
Step 4: Insert the block into offer descriptions
On Allegro, in Shopify, on Etsy – wherever you have an online offer. Place the CLP block at the end of the product description or in a dedicated "Safety Information" section. You don't have to make it the dominant element of the offer – it should be accessible, not flashy.
Step 5: Update photos (optional)
The regulation refers to "information" in the offer, not pictograms in photos. You don't have to include pictograms on product photos – it's enough in the text description. But some platforms (Amazon) may have their own requirements for photos.
5. Green claims – beware of "eco" claims
The CLP amendment 2024/2865 also introduces rules regarding environmental claims (green claims) on labels and in advertising. You cannot write "eco", "natural", "environmentally friendly" on a candle if the mixture is simultaneously classified as hazardous to the environment (H410, H411, H412).
For candle makers, this is important – many fragrance oils contain substances with environmental classification. If your candle has H412 on the label, writing "natural eco candle" in the offer is non-compliant with the new regulations.
What you can write:
- "Soy wax candle" – this is a fact, not an environmental claim
- "100% plant-based wax" – description of an ingredient, not a claim about the entire product
- "Cotton wick" – description of the material
What to avoid:
- "Eco candle" – if the mixture is environmentally classified
- "Safe for the environment" – if it has H411 or H412
- "100% natural" – if the fragrance oil is synthetic (and most fragrance oils are)
- "Non-toxic" – if it contains substances classified as toxic
Principle: Describe ingredients (soy wax, cotton wick), do not make claims about the entire product that you cannot prove or that contradict the CLP classification.
6. Social media – Instagram, Facebook, TikTok
Do the new requirements apply to Instagram posts? It depends on the interpretation:
- Post with a link to the store – if the post directs to the purchase of a hazardous product, it is technically "advertising" in the CLP sense. From 2028, it should contain CLP information or direct to a page that contains it.
- Brand image post (without a purchase link) – a photo of a candle with the description "evening with a candle" without a link to the store is content marketing, not product advertising. It does not require pictograms.
- Instagram Shop / Facebook Shop – this is already a sales offer. Treat it as an online store – CLP requirements apply.
Practical advice: in the profile bio or in the post description with a link, add: "Full product safety information on the store's website." And make sure this information is on the product page.
7. Frequently asked questions
"My candle is not hazardous – do I need to change anything?" – No. If the candle does not have CLP pictograms (because you stay below the threshold), the new online advertising requirements do not apply to you. Sell as before.
"Do I need to put GHS pictograms on product photos?" – No. Pictograms must be in the offer description (text + image), not on lifestyle photos. But make sure they are visible somewhere in the online offer.
"What about Allegro – will Allegro enforce these changes?" – Probably yes. Allegro already verifies compliance with GPSR. When the CLP requirement for online advertising comes into force (2028), Allegro will most likely add a dedicated field for pictograms and hazard statements – just as it added GPSR fields.
"This will discourage customers – pictograms in the offer look terrible" – We understand the concern. But it's better to be transparent than risk blocking the offer. Moreover: you educate customers. Blog articles (like ours!) explain that pictograms on a candle do not mean "poison" – they mean "classified product, with information on safe use." Transparency builds trust.
"Can I avoid this problem?" – Yes – by choosing a concentration below the classification threshold. Unclassified candle = no pictograms on the label = no pictograms in the online offer = no problem.
Summary
New online CLP advertising requirements (2024/2865) come into force on January 1, 2028. They apply ONLY to candles classified as hazardous. If your candle does not have pictograms – nothing changes.
Three rules:
- Know the classification of your candle – this determines everything: the label, UFI, PCN, and now also online advertising
- Below threshold = zero advertising formalities – another reason to choose concentration consciously
- Prepare in advance – don't wait until December 2027. CLP block template, pictogram graphics, updating descriptions – do it once and you're set
At TopWosk, we provide the classification threshold for each fragrance oil – you immediately know if your candle will require pictograms in the online offer. And our CLP Label Generator includes ready-made GHS pictogram graphics that you can also use in offer descriptions. Check out our fragrance oils with Safety Package →