From a chemical point of view, candles are considered “mixtures” on a carrier (the wick). As a result, candles fall within the Classification, Labeling and Packaging (CLP) and associated UFI code legislation.
Candles consist mainly of harmless wax that does not need to be classified. Candles usually contain fragrance and color additives, some of which can be dangerous. If present in high enough concentrations, warnings or pictograms may be required.
A summary of the CLP regulation
The CLP regulation requires manufacturers, importers and downstream users of products containing hazardous mixtures to add a UFI code to their product labels.
The CLP regulation is valid in the European Economic Area (EEA). This includes all 27 member states as well as Norway, Iceland, Liechtenstein and Switzerland – the latter is subject to additional special rules.
What is the UFI (Unique Formula Identifier)?
The UFI code helps to clearly identify a hazardous mixture, allowing poison centers to provide necessary first aid and advice more quickly by establishing a direct and unique link between the mixture being marketed and the associated safety information.
UFI codes are always encrypted data forms, meaning that unauthorized third parties cannot obtain information about the composition of the mixture. Suppliers can therefore pass the code along the supply chain without worry.
This code is linked to a central database that contains safety information about each hazardous mixture. The capabilities of variable online code printing in production lines increases the flexibility, versatility and reliability of manufacturer’s production and processes.
When and where is a UFI code applied?
The CLP regulation requires the UFI code to be added to the product label and safety data sheet. The UFI code should be printed in a clearly visible place on the label (for example, near the bar code or hazard pictograms).
It is important to note that the UFI code always refers to the mixture in the product. For example, the UFI code does not need to be changed if the brand name or label of the product changes.
The same does not apply if the composition of the mixture is changed. In that case, a new UFI code is required and the changes must be communicated to the relevant authorities. This is also necessary when the composition of a supplied mixture changes.
A dangerous mixture may also have multiple UFI codes. For example, if products A and B contain the same mixture, each “commercial product” should have its own UFI. The same UFI code cannot be valid for multiple mixtures.
When is a UFI code not required?
If the MSDS does not contain a hazard pictogram depicting a human hazard, there is no need to include a UFI on the label or safety data sheet.
If a candle contains a sensitizing fragrance ingredient of more than 0.1% (the proportion can also be lower, for fragrances with a special limit) but less than 1%, the label must include the statement:
“Contains (name of sensitizing substance). May cause an allergic reaction.”
In this case, however, both the UFI code and the PCN notification are not necessary, because the candle is not classified as hazardous to health (with H3… sentence).
When is a UFI code required?
You must submit a PCN notification for mixtures classified for health hazard (H3..) or physical (H2..).
If the product label contains a hazard pictogram depicting a hazard to humans, the UFI must be indicated on the label or in the safety data sheet.
If a candle contains a total of more than 1% sensitizing fragrances, the candle must be marked with the exclamation point icon, the signal word WARNING and the statement, “May cause allergic skin reaction.” – and a list of chemicals that contributed to the classification. In this case, both a UFI code and a PCN notification are required.
