What is CLP?
Classification, Labelling and Packaging — the legal framework requiring hazard communication on products containing chemicals.
⚠️ Do I need a CLP label?
If the finished product is classified as hazardous, the applicable labelling requirements must be addressed before selling. This applies regardless of business size. Verify the current supplier SDS and authoritative guidance.
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.
GB CLP scope
GB CLP applies in England, Scotland and Wales. HSE describes manufacturers, importers, downstream users and distributors placing chemicals on the GB market as suppliers, with duties depending on their role in the supply chain. CLPeasy currently focuses on labels for the Great Britain market.
EU CLP — Regulation (EC) No 1272/2008 EU
CLPeasy currently focuses on Great Britain. EU requirements can differ and should be checked separately using current official guidance.
⚠️ Selling outside Great Britain
Do not assume a GB label is suitable for the EU, Northern Ireland or another market. Requirements and transition dates can differ. CLPeasy does not currently provide EU or Northern Ireland-specific label support, so check current official guidance for the market where you intend to supply the product.
If you sell into the EU
UK makers selling to EU consumers must check and comply with the current EU CLP requirements, including responsible-person and language requirements. CLPeasy currently focuses on GB labels.
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
Northern Ireland can follow different requirements from Great Britain. Check current official guidance before supplying products there; CLPeasy currently focuses on GB labels.
✓ Safest approach
Do not assume a GB label is suitable for another market. Check that market's current responsible-person, language and other labelling requirements separately.
What must go on a CLP label?
Depending on the classification, a GB CLP label may need the following elements. Verify current requirements against authoritative guidance.
- 1Product name / identifierThe name of the product or scent as it appears on your product
- 2Supplier detailsThe name, address and contact information required for the supplier placing the product on the Great Britain market
- 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"
- 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). Hazard statements are found in Section 2.2 (Label elements) of your SDS. Copy that complete section into Smart Paste and review the extracted information against the source document.
| 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
Copy the complete Section 2.2 (Label elements) into Smart Paste. Do not paste the rest of the document, as later sections can contain codes or terminology that do not belong on the product label. Always use the current SDS applicable to the exact fragrance load, finished-product concentration and target market.
Use current, applicable supplier information
Safety Data Sheets are an important source of classification and labelling information, but your duties depend on your role and the product you place on the market. HSE states that a downstream user who changes the composition of a mixture must classify it in line with GB CLP before placing it on the market.
Using your current supplier information avoids relying on a stored copy that may be outdated. Make sure the information you use is applicable to your product, composition, fragrance load and the Great Britain market, and review the finished label before use.
CLPeasy reads Section 2.2 (Label elements) of your SDS. Copy that complete section—from its heading through the final hazard, precautionary and supplemental information—and paste it into Smart Paste. Do not paste the entire SDS, as unrelated information from later sections could be extracted by mistake.
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. Copy Section 2.2 (Label elements) into Smart Paste and CLPeasy extracts the available sensitiser information for you to review against your SDS.
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.
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.
International chemical-labelling reference Outside Great Britain
General reference information for makers researching requirements outside Great Britain. Jurisdictions implement chemical-labelling rules differently, so always verify the rules for the market where you supply.
⚠️ CLPeasy currently focuses on Great Britain
CLPeasy currently focuses on labels for the Great Britain market (England, Scotland and Wales). Requirements outside Great Britain differ. If you supply Northern Ireland or another country, check the rules that apply in that market.
⚠️ 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; verify current official guidance |
| 🇪🇺 EU | EC 1272/2008, 2023/707, 2024/2865 | Rev 7+ | Separate market requirements apply; verify before exporting |
| 🇺🇸 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 — What You Need to Know
Combining fragrance oils creates a new mixture. Your label must be based on classification information for your finished product, not on the individual oils’ safety data sheets.
🚨 A fragrance blend is a new mixture
If you combine two or more fragrance oils, your finished product contains a new mixture. Before you supply it in Great Britain, your finished product needs appropriate GB CLP classification information that covers the product as a whole.
That classification cannot be established simply by combining the hazard and precautionary statements from each fragrance oil’s safety data sheet (SDS). It depends on the ingredients in your finished product and how much of each is present. Classification should be carried out by someone with the scientific competence to do so.
⚠️ What CLPeasy can and cannot do
CLPeasy cannot calculate the classification of a custom fragrance blend. It can build your label from suitable classification information that covers your blend in your finished product.
Your fragrance supplier may be able to provide classification information, or an SDS, for a custom blend on request. A qualified CLP specialist can also help.
Official GB CLP & Reference Links
Authoritative GB CLP sources first, followed by clearly separated EU and international reference material.
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