This article was updated on 01/27/2021
A new labeling element will be required on the labels of certain products from 2021: a 16-character code called a unique formulation identifier (UFI). From 01/01/2021, the UFI must appear on the label of all products classified with regard to health hazards and physical dangers in the European Economic Area (EEA).
As we saw in a previous article on CLP labeling, the sale of candles, melts and derivatives is regulated.
A regulation, not so new, is being put in place and we will try to enlighten you a little (by candlelight).
What are these new regulations regarding candle labels?
Decree No. 2014-128 of February 14, 2014 relating to toxicovigilance defines products requiring mandatory declaration according to their classification.
Manufacturers are legally required to declare certain products to an approved body according to this classification.
In other words, everyone responsible for placing a product on the market is encouraged to make the declaration in order to make available to INRS and CAPTV all information necessary for evaluating the risk induced by exposure to a product and medical treatment in the event of poisoning.
In this specific case, it is a registration using a UFI number or Unique Formulation Identifier, a 16-character code which must be affixed to the labels of products classified as dangerous and which will make it possible to easily identify a mixture in the event of a call to the poison control center. This animation (activate the subtitles), you will learn a little more.
What should you declare? When ?
The good news is that not all products offered for sale will necessarily be subject to registration.
Indeed, you must take into account the classification of your finished product and, although the list of danger categories to declare has continued to grow over the years, without any real obligation until then, ultimately many of your finished products will not need to be registered.
For example, a natural candle, without perfume, will not need to be registered since it does not contain substances classified as dangerous.
For all perfumed products, whether candles, fondants, diffusers and so on, it will be necessary to declare those which are classified in certain categories.
This becomes an obligation from January 1, 2021 for new products, and for existing products, if they have not already been declared on Synapse.
And so, what are the categories to declare?
Overall, your finished products are rarely classified as very dangerous. You will therefore only be concerned if your product is classified as dangerous for health, that is to say all "H" mentions starting with 3, or if it is classified as a physical danger, this is i.e. all “H” mentions starting with 2, except: H200, H201, H202, H203, H204, H205, H280, H281.
Please note, the mention EUH208, “contains… May produce an allergic reaction”, is not a classification but information. It therefore does not entail any declaration obligation.
Okay, but how do I do that? How much will it cost me?
Good news, submitting your UFI declarations is free for France on the ECHA European platform.
And after ?
At the time of writing this article, Belgium and Luxembourg have not yet validated the ECHA platform, this should be done in the coming weeks.
Switzerland is not subject to this regulation if you do not sell outside Switzerland.
To go further, we support you
We are informed and specialized in legal obligations, so our team remains at your disposal to support you in these procedures. You can also find an article dealing with complex regulations concerning fondants.
