What is CLP?
Classification, Labelling and Packaging — the legal framework requiring hazard communication on products containing chemicals.
⚠️ Do I need a CLP label?
Yes — if your product contains any hazardous ingredient (which most scented products do, due to fragrance oils), you are legally required to produce a CLP-compliant label before selling. This applies to all makers regardless of size — cottage industry sellers follow the same rules as large manufacturers.
What is CLP?
CLP stands for Classification, Labelling and Packaging. It requires anyone who sells products containing hazardous chemical substances — including products — to clearly communicate those hazards on the product label using standardised symbols, signal words and statements.
✓ Unscented products
If your product contains no hazardous substances — for example a pure unscented beeswax candle — you may not require a CLP label. However you must still comply with GPSR general product safety requirements. Always check with Trading Standards if unsure.
UK CLP — Great Britain GB
England, Scotland and Wales follow retained EU law via the European Union (Withdrawal) Act 2018, administered by the HSE.
Key differences from EU CLP for GB labels
• Labels must reference the GB responsible person (your name, address and contact details)
• UFI registration goes to the GB NPIS system — not the EU ECHA system
• Labels use GHS pictograms (same symbols as EU CLP)
• The HSE is the enforcement body in Great Britain for larger operations
• For retail sales, Trading Standards are your primary enforcement contact
EU CLP — Regulation (EC) No 1272/2008 EU
The core EU regulation, amended in 2023 and 2024 with significant 2026 requirements now in force.
⚠️ 2026 Update — now in force
Regulation (EU) 2023/707 is mandatory from 1 May 2026 for all new products placed on the EU market. SDS sheets must be updated even for products containing no endocrine disruptors, as this must now be clearly stated on the SDS. Check with your fragrance supplier that their documents are 2026 compliant.
⚠️ CLP 2024/2865 — new label formatting rules
Published November 2024, in force December 2024. New rules include mandatory minimum font sizes, text must be black on white background, line spacing at least 120% of font size, and new digital labelling provisions. These may require larger labels on some products.
If you sell into the EU
UK makers selling to EU consumers must comply with EU CLP — not just UK CLP. This includes having an EU Responsible Person if you are not based in the EU, and registering your UFI with the EU ECHA system (mandatory since January 2025).
Northern Ireland — Windsor Framework EU CLP
Northern Ireland follows EU CLP — not UK CLP — under the Windsor Framework.
Northern Ireland follows EU CLP — not UK CLP
Under the Windsor Framework, Northern Ireland remains aligned with EU single market rules for goods. Products sold in Northern Ireland must comply with EU CLP, including EU UFI registration which has been mandatory since January 2025. If your customers include Northern Ireland buyers, you may technically need EU CLP-compliant labels.
✓ Safest approach
Produce labels compliant with both GB and EU CLP requirements. The core label content is very similar — the main differences are around the Responsible Person details and UFI registration system. CLPeasy will offer dual UK/EU label generation in a future update.
What must go on a CLP label?
A CLP-compliant label for a scented product must include all 10 of the following elements.
- 1Product name / identifierThe name of the product or scent as it appears on your product
- 2Responsible person detailsYour full business name, address and contact details — the person legally responsible for the product's compliance
- 3Net quantityThe weight or volume of the product (e.g. 200g, 85ml)
- 4Hazard pictograms (GHS symbols)The relevant GHS diamond-shaped hazard symbols determined by your fragrance's hazard classification
- 5Signal wordEither DANGER or WARNING — determined by the hazard classification at your fragrance load percentage
- 6Hazard statements (H statements)Standardised phrases describing the hazard — e.g. H317 "May cause an allergic skin reaction"
- 7Precautionary statements (P statements)Standardised phrases advising safe handling — e.g. P102 "Keep out of reach of children"
- 8Allergen declaration (EUH208)If the fragrance contains classified skin sensitisers above threshold — "Contains [name]. May produce an allergic reaction"
- 9UFI (Unique Formula Identifier)Mandatory for EU/NI sales since January 2025. Voluntary but recommended for GB sales
- 10Batch / lot numberA code allowing the product to be traced back to a specific production batch
H & P Statements
Standardised codes and phrases that describe hazards (H) and safe handling instructions (P). Found in your SDS Section 2.2.
| Code | Statement | Type |
|---|---|---|
| H226 | Flammable liquid and vapour | Physical |
| H302 | Harmful if swallowed | Health |
| H304 | May be fatal if swallowed and enters airways | Health |
| H315 | Causes skin irritation | Health |
| H317 | May cause an allergic skin reaction | Health |
| H319 | Causes serious eye irritation | Health |
| H361 | Suspected of damaging fertility or the unborn child | Health |
| H400 | Very toxic to aquatic life | Environmental |
| H410 | Very toxic to aquatic life with long lasting effects | Environmental |
| H411 | Toxic to aquatic life with long lasting effects | Environmental |
| H412 | Harmful to aquatic life with long lasting effects | Environmental |
| EUH208 | Contains [name]. May produce an allergic reaction | Allergen |
✓ Where to find your H statements
Your fragrance supplier's SDS Section 2.2 (Label elements) lists all H statements that apply at the stated concentration. Always use the SDS for the exact fragrance load you use in your product.
EUH208 & Sensitisers
If your fragrance contains classified skin sensitisers above threshold, EUH208 must appear on your label.
Threshold concentrations
• Category 1A sensitisers: declare at ≥ 0.01% in the finished product
• Category 1B sensitisers: declare at ≥ 0.1% in the finished product
Your SDS Section 2.2 lists which sensitisers are present and at what classification level.
Common sensitisers to check for
Geraniol, Linalool, Linalool (oxidised), Citral, Limonene, Citronellol, Eugenol, Benzyl alcohol, Benzyl benzoate, Coumarin, Isoeugenol, Cinnamal, Farnesol, Hydroxycitronellal, Lilial, Lyral, Methyl 2-octynoate and others. CLPeasy has a built-in library of all 28 common CLP fragrance sensitisers.
UFI — Unique Formula Identifier
A 16-character code linking your product to poison centre data — mandatory for EU/NI, voluntary for GB.
✓ Generate your UFI for free
Visit ufi.echa.europa.eu to generate your UFI code for free. For GB: register with the UK National Poisons Information Service (NPIS). For EU/NI: register via the ECHA PCN portal. CLPeasy includes a UFI field so you can add your code directly to your label.
REACH Regulation UKEU
Governs chemical substances. As a product maker you are typically a downstream user — your fragrance supplier handles REACH registration.
Your responsibilities under REACH
As a downstream user, your fragrance supplier handles substance registration. However you are still responsible for using compliant materials and applying correct CLP labelling. UK REACH and EU REACH may diverge over time — check both if you sell into both markets.
✓ Practical advice
Ask your fragrance supplier to confirm their products are REACH compliant and that their SDS is up to date. A current SDS from a reputable UK supplier is your primary protection as a downstream user.
GPSR — General Product Safety Updated Dec 2024
All consumer products must be safe under normal use — beyond CLP labelling. EU GPSR came into force December 2024.
⚠️ Selling online to EU customers — December 2024 onwards
Since December 2024, if you sell products to EU consumers (including via Etsy, Folksy or your own website), you must comply with EU GPSR Regulation 2023/988. This includes having a Responsible Person established within the EU. Non-compliant products can be removed from online marketplaces.
GPSR requirements for products
• Your product must be safe under normal use
• Adequate burning instructions and warnings must be provided
• Packaging must be secure and not create hazards
• You must be able to trace and recall products if needed
• If selling to EU: may need an EU Responsible Person
IFRA Standards Global
International Fragrance Association standards set maximum usage levels for fragrance ingredients by product category.
IFRA and product makers
Your fragrance supplier's IFRA certificate lists the maximum recommended fragrance load per product category. Staying within IFRA limits helps ensure your CLP hazard classification remains accurate. Note: IFRA compliance is separate from CLP — a fragrance may be IFRA compliant but still require a CLP label.
✓ Ask your supplier for IFRA certificates
Reputable UK fragrance suppliers will provide an IFRA certificate for each fragrance alongside the SDS. Keep these on file as part of your compliance records.
Global CLP & GHS Laws by Country Worldwide
Most countries base their chemical labelling laws on the UN GHS framework — but each implements it differently. Always verify before exporting.
⚠️ Always verify before exporting to any country
Regulations change frequently. The table below is a general guide only. Before selling products into any country, always verify the current requirements with an official source or a qualified compliance professional in that country.
| Country | Regulation | GHS | Key notes |
|---|---|---|---|
| 🇬🇧 UK | UK CLP (EC 1272/2008) | Rev 7+ | HSE / Trading Standards. UFI voluntary for GB |
| 🇪🇺 EU | EC 1272/2008, 2023/707, 2024/2865 | Rev 7+ | UFI mandatory Jan 2025. 2026 SDS update required |
| 🇺🇸 USA | OSHA HCS 29 CFR 1910.1200 | Rev 7 (2024) | Mixtures compliance deadline July 2027. Enforced by OSHA |
| 🇨🇦 Canada | WHMIS 2015 + CCPSA | Rev 7 | Consumer products also governed by Canada Consumer Product Safety Act |
| 🇦🇺 Australia | Safe Work Australia WHS Regulations | Rev 7 | Consumer safety governed by ACCC. Check ACCC for candle specifics |
| 🇳🇿 New Zealand | HSWA Hazardous Substances Regs 2017 | Rev 6/7 | Administered by WorkSafe NZ |
| 🇯🇵 Japan | ISHA + JIS Z7252/Z7253 | Rev 6 | Verify current requirements with local specialist before exporting |
| 🇰🇷 South Korea | Chemicals Control Act + K-REACH | Rev 7 | Importers must register with Korean government |
| 🇨🇳 China | GB 30000 series | Rev 8 (Aug 2025) | Mandatory national catalogue. Local specialist advice essential |
| 🇸🇬 Singapore | WSH Act | Rev 7 | Also subject to Consumer Protection (Fair Trading) Act |
| 🇮🇳 India | MSIHC Rules 1989 (amended) | Partial GHS | Progressive GHS adoption — specialist advice recommended |
| 🇿🇦 South Africa | OHS Act + SANS standards | Partial GHS | GHS adoption in progress. Local specialist advice recommended |
✓ The UN GHS reference — the Purple Book
The United Nations publishes the master GHS document that all national regulations are based on. Freely available at unece.org/transport/dangerous-goods/ghs-rev10-2023
Blended Fragrances — Important Legal Warning
Combining fragrance oils creates a new chemical mixture that requires its own SDS and hazard assessment.
🚨 Blending fragrances creates a new mixture requiring its own CLP assessment
If you combine two or more fragrance oils to create a custom scent, the resulting blend is legally a new chemical mixture. You cannot simply use the individual SDS sheets — the combined hazard classification must be calculated for the blend as a whole. Before releasing a blended fragrance product to the public, industry best practice requires a new SDS for the blend from a fragrance house or safety assessor, combined hazard classification verified, and labels generated based on the blend's SDS — not the individual components.
⚠️ CLPeasy currently supports single-fragrance products only
If you blend fragrances, please consult your fragrance supplier or a qualified safety assessor before generating any CLP labels. Some fragrance suppliers will produce a combined SDS for custom blends on request. Specialist CLP compliance consultants can also assist.
Official Legislation & Reference Links
All the official sources in one place — legislation, guidance and tools.
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