The CLP Regulation
CLP is a European Regulation (EC) No 1272/2008 and is short for classification, labelling and packaging of substances and mixtures which may contain substances harmful to health or environment. the regulation came into force on 20 January 2009 in all EU Member States, including the UK. It is known by its abbreviated form, ‘the CLP Regulation’ or just plain ‘CLP’.
With regard to candle making , CLP primarily relates to the use of fragrance oils or dyes, although that is not exhaustive and it is intended that any harmful substance contained within the mixture, that may or can cause reactions harmful to health or the environment, will be identified on the product packaging, along with warning pictogram/s , details of the chemical, hazard reference and mitigation of the hazard.
The CLP Regulation adopts the United Nations’ Globally Harmonised System on the classification and labelling of chemicals (GHS) across all European Union countries, including the UK.
As GHS is a voluntary agreement rather than a law, it has to be adopted through a suitable national or regional legal mechanism to ensure it becomes legally binding. That’s what the CLP Regulation does.
As GHS was heavily influenced by the old EU system, the CLP Regulation is very similar in many ways. The duties on suppliers are broadly the same: classification, labelling and packaging.
The existing legislation on classification, labelling and packaging has been agreed at European Union level and, from 2015, will be directly applied on all EU member states, including the UK, although when we leave the EU regulations may change.
The rules they have to follow when they are classifying will change though, and a new set of hazard pictograms (quite similar to the old ones) are used:
GHS hazard pictograms
Like most regulations stemming from Europe, there are confusing sections, for instance, regarding the labelling of Fragrance Oil volume below 125ml, or indeed for candles and melts themselves, however as some substances as low as 0.001% can cause a reaction , it is important to quantify the substances contained within your mixture (wax melts or candles) .
An original and popular guide line was, if any substance above 1% by weight, should be identified on your labels, along with any relevant pictograms however as we have shown earlier, some substances can provide a hazard at much lower quantities, so this catch all +1% method is not entirely correct.
The regulations also now suggest naming no more than four substances on your label is acceptable, but we find this is contradicting the basic regulation, and believe if it contains substance which can affect perfume sensitivity, then it is safer to incorporate these in your labelling or packaging.
Secondly you must consider the size of the product and for very small volumes, your label may not be big enough to contain all of the relevant information, there are a number of FO suppliers out there whom supply oils in small test tubes without any identification at all, they rely upon the customer accessing the SDS on their website to gather advise, this is clearly not a suitable method to identify any hazards.
Other companies are offering a CLP label for the oils they sell, based on a fragrance load of 10%, however with new soy waxes capable of taking 15 -20% fragrance load, and reactions may occur with exceedingly low level of some substances, this is clearly insufficient way to label your products..
The regulations further confuse users and creators of labels/packaging by not requiring the exclamation mark to be used with some of the other pictograms , such as when you need to use the fire hazard pictogram.
You will find most candles and wax melts bought from high street stores are labelled with hazard and treatment instructions, although we did notice that some stores, including Dunelm had no information on their candles and fragrance oils, generally this is not the case and perhaps the easiest way to identify your labelling requirements is to follow their lead and produce similar labels based on your specific FO or Dye product.
You will find commonly used materials within your FO, as fragrance oils use many of the same ingredients, so many of the H warnings are common to many different fragrance oils, and you will see these h numbers occurring time and again.