Any product placed on the market must have an individual safety data sheet, labeling according to CLP standards and/or AFNOR labeling. We present to you all the terms and conditions to be respected.
In a world where the quality and safety of consumer products are increasingly important, it is essential to understand and comply with the regulations in force for candles and scented wax melts. Whether you are an individual or a professional, this article will help you navigate the legal obligations, AFNOR and CLP regulations, as well as the necessary labeling for your products.
We will cover the different situations you may face, the health and environmental risks, and the steps to take to ensure your products are compliant.
Finally, we will present innovative solutions to avoid CLP labeling and offer you advice on how to successfully create your labels and safety data sheets.
Article updated on 02/21/24
Who is concerned?
Depending on your situation, the regulations are not the same.
I am an individual
When you produce candles or scented pebbles privately, for your own use or for your loved ones, you have no special obligations, except to store your products away from light and out of reach of children. Good news, right?
I am a professional
Now it's going to get complicated...
You sell candles or melts, whether you sell them at home, at a market or in a store, you have an obligation to follow established regulations.
Please note: The DGCCRF (General Directorate for Competition and Consumer Affairs) regularly checks points of sale.
Legal requirements for candles and melts
Failure to take this into account in the event of an inspection can have very serious criminal and administrative consequences (up to €50,000 fine and 3 years imprisonment).
What regulations are we talking about?
The AFNOR regulation is a European standard relating to safety against the fire risks of candles. It only concerns candles.
The CLP (Classification Labelling Packaging) regulation is a European regulation aimed at informing consumers of health and environmental risks.
Yes, but then why these regulations?
We live in an era where we increasingly attach importance to the quality and risks that all our consumer products represent.
The AFNOR regulation therefore helps prevent the risks associated with the combustion of candles as well as the dangers of fires, and recommends advice on their use. This regulation was put in place to prevent the risks associated with the combustion of candles and the dangers of fires, and it recommends advice on how to minimize these risks.
Since January 1, 2019, AFNOR labeling consists of 9 mandatory pictograms (GHS 01 to SGH09), including a triangle containing an exclamation mark and 8 other pictograms that provide safety advice on the use of candles. It is important to comply with these regulations to guarantee the safety of your customers and avoid any risk of fire.
The CLP regulation indicates the potential risks associated with releases into the environment as well as the potential dangers of allergy, irritation, concerning the skin, eyes or even respiratory risks. Thus, a sensitive person or person prone to allergies may consider that the use of this product represents a potential danger for them.
What are my obligations in this case?
Any product placed on the market must be subject to an individual safety data sheet, labeling according to CLP standards and/or AFNOR labeling.
Every product subject to the CLP standard must be packaged, the consumer must not be in direct contact with the product under any circumstances. In case you sell to professionals, the safety data sheet must be provided, whereas if you sell your product to an individual, you will only have to provide it if the latter asks you for it.
The CLP label must have minimum dimensions of 74 x 52 mm.
If it is smaller, the pictograms must be at least 1:15 of the total size of the label.
What's on these labels?
Since January 1, 2019, AFNOR labeling has consisted of 7 mandatory pictograms (NB: before this date, only 5 pictograms were mandatory).
You will find a triangle containing an exclamation mark, accompanied by 6 pictograms intended to provide safety advice on the use of candles.
Other optional pictograms may be used depending on the intended end use.
The CLP label contains hazard pictograms if necessary, your contact details, information on health or environmental hazards, safety advice, precautions for use, and the list of possible sensitizing or allergenic substances, according to certain thresholds imposed by the regulations.
Please note that since January 1, 2021, certain precautionary statements have become strongly recommended in certain cases even if the product is not classified as dangerous, namely phrases P101, P102 and P103.
Let's talk about the precautionary advice P102, which aims to protect children. Even if this advice is optional, it is strongly recommended to include it on your labels.
For what ?
Because if an accident involving children occurs and you have not indicated this advice, the case law of the courts will not support you. In other words, you are better protected legally by adding it, even if it is not a strict obligation.
These 3 safety tips are to be indicated in certain cases. If, for example, you are subject to more important safety tips (related to the danger on the skin for example) then these will take priority. Otherwise, please indicate tips P101, P102 and P103
Finally, any product whose production and labeling are prior to this date can be sold as is until the stock is exhausted.
Concretely, what labeling for what type of product?
So here's what you'll need to include in your articles:
- For scented candles: CLP label (systematic since January 1, 2021) + AFNOR.
- For unscented candles: AFNOR label.
- For scented pebbles or “melts”: CLP label.
- For unscented pebbles or “melts”: no labeling.
For which countries?
If you sell products abroad, you must adapt the safety data sheets AND labels in the language(s) of the country of sale.
CLP standard: This is the standard in force in Europe.
The GHS has been adopted by many countries around the world and today (e.g. USA) it serves as a reference in the development of international regulations.
Please note: if you buy your raw material abroad, you must be able to present a safety data sheet in French and have labeling on your products that complies with the CLP regulation and not GHS, your supplier must be able to provide you with these documents...
I often see candles in supermarkets that do not have this CLP labeling, why?
A handmade candle or melt has little in common with the industrially manufactured products found in supermarkets. The major difference lies in the composition, in particular the quality and percentage of the fragrance used.
Unlike artisanal creations which favor high quality ingredients, industrialists frequently opt for lower quality chemically synthesized perfumes.
These fragrances, not from the renowned perfumers of Grasse, are also used in low concentrations. This choice limits the olfactory rendering, but allows manufacturers to pass under the classification thresholds imposed by the CLP regulation. Thus, they avoid the detailed labeling of components, generally required for products containing a greater quantity of fragrances.
I want to avoid CLP labelling, what should I do?
All 1% fragrances are not subject to UFI declaration for your candles, making it easier to market your scented candles.
You will agree that they represent an innovative solution to allow you to create high quality candles at a significantly reduced cost. Each fragrance in our Boost range does not require a UFI declaration in 1% dosage .
By dosing at 1%, each candle or melt containing one of our 9 fragrances is not subject to the mandatory CLP labelling information, namely:
- Monoi
- Cotton Flower
- Red Fruits
- Hazelnut Burst
- Rhubarb Spritz
- Orange blossom
- Spiced apple
- Forest fruits
- Christmas tree
These 9 fragrances are not subject to the UFI declaration or the mandatory warning statements of the CLP label for a dosage of 1%. The Safety Data Sheet (SDS) may sometimes mention precautionary advice such as P101 or P103, but their presence is optional.
However, it is strongly recommended (where applicable) to include the precautionary statement P102, although it is also optional.
Please note: you must indicate the product identifier, weight and your contact details (name, address, telephone) on the label. Labeling according to AFNOR standards also remains mandatory for candles.
Boost your life fragrance is only exempt from the 1% UFI declaration.
New CLP regulation and impact on SDS: What you need to know
Here is some crucial new information regarding the CLP regulation and the resulting changes to SDSs. First of all, it is essential to know that the current CLP regulation is 2023/707. By 2025, the consideration of endocrine disruptors and nanoparticles will become mandatory for substances, and in 2026 for mixtures.
Please also note that a new version of the CLP memento is expected for the end of 2023. This means that the SDSs will have to be updated, even for products that do not contain endocrine disruptors or nanoparticles, since this will have to be clearly indicated on the SDSs.
Finally, IFRA 51 has been launched since summer 2023, and the number of allergens to monitor will increase from 26 to more than 80. However, don't worry too much for now. The application date of the new CLP 2023/707 regulation is set for May 1, 2026.
We therefore advise you to regularly check the official sources available at the bottom of the page. We will also update this article daily.
Need support to create your labels and safety data sheets?
With our expertise for professionals, we can support you in facilitating and organizing the implementation of this compliance.
Contact us via the form, our safety and legislation expert will advise you. We also offer complete training related to safety data sheets and/or legislation.
Sources:
Discover the CLP regulation memo.
