EUH208 Explained: Which Allergens Must You Name?
If you sell scented candles in the UK or EU, there's one label element that trips up more makers than any other: EUH208.
This mandatory statement requires you to name the specific allergens present in your product. Get it wrong and your label is non-compliant — even if everything else is perfect.
What Is EUH208?
EUH208 is a supplementary hazard statement under CLP Regulation (EC) No 1272/2008. The exact wording is:
"Contains [name of sensitising substance]. May produce an allergic reaction."
It must appear on the label whenever a fragrance component that is classified as a skin or respiratory sensitiser is present above its special-labelling threshold — even when the finished candle itself is not classified as sensitising. Importantly, CLP has no fixed “allergen list” and no rinse-off/leave-on split — those belong to the separate cosmetics regime; the trigger is each component's own CLP classification.
The Thresholds: When Does EUH208 Trigger?
There is no rinse-off/leave-on table for candles. EUH208 thresholds follow the component's own sensitiser classification (CLP Annex I, Table 3.4.6 — the same thresholds used for the SDS concentration-for-mixing table):
| Sensitiser classification of the component | EUH208 threshold in the finished product | If the concentration is higher |
|---|---|---|
| Skin/Resp. Sens. Cat. 1 or 1B | ≥ 0.1% (1,000 ppm) | ≥ 1.0% → the mixture is classified H317 |
| Skin/Resp. Sens. Cat. 1A | ≥ 0.01% (100 ppm) | ≥ 0.1% → the mixture is classified H317 |
| Component with a specific concentration limit (SCL) | One-tenth of the SCL | ≥ SCL → the mixture is classified H317 |
For a typical candle — whose fragrance components are mostly Cat. 1/1B sensitisers such as Linalool and Limonene — the practical threshold is 0.1% of the component in the finished product. These are the established CLP rules; the 2026 UK amendments do not move candles onto any cosmetic-style 0.001% threshold.
Sensitisers Commonly Found in Fragrance Oils
There is no single “EUH208 list”. A substance triggers EUH208 because it carries a CLP skin/respiratory sensitiser classification in CLP Annex VI (or the GB MCL list) — or is classified as such in your supplier's SDS. The fragrance materials below are common examples with established sensitiser classifications:
| Allergen Name | Common In | SDS Reference |
|---|---|---|
| Linalool | Lavender, floral blends | CAS 78-70-6 |
| Limonene | Citrus, fresh scents | CAS 5989-27-5 |
| Geraniol | Rose, floral scents | CAS 106-24-1 |
| Citronellol | Rose, citrus blends | CAS 106-22-9 |
| Eugenol | Spice, clove, chai | CAS 97-53-0 |
| Coumarin | Vanilla, tonka, sweet | CAS 91-64-5 |
| Alpha-Isomethyl Ionone | Violet, woody, iris | CAS 127-51-5 |
| Hexyl Cinnamal | Jasmine, floral | CAS 101-86-0 |
| Benzyl Salicylate | Floral, balsamic | CAS 118-58-1 |
| Farnesol | Lily of the valley, floral | CAS 4602-84-0 |
| Evernia Prunastri (Oakmoss) | Chypre, woody | CAS 90028-68-5 |
| Evernia Furfuracea (Treemoss) | Chypre, fougère | CAS 90028-69-6 |
Remember: Annex III of CLP holds the wording of hazard statements; it is not an allergen list. Whether a specific chemical — or a natural extract such as oakmoss — must be named depends on its current CLP / GB MCL classification, which is why every assessment starts from the dated SDS on file.
How to Calculate Whether EUH208 Applies
Step-by-step calculation
1. Get the SDS for your fragrance oil — read Section 3 for each component, its concentration and its classification.
2. Flag every component classified as a skin or respiratory sensitiser (Annex VI/GB MCL or the supplier's classification), and note any specific concentration limit.
3. Multiply each component's concentration by your fragrance load to get its concentration in the finished product.
4. Apply CLP's additive logic for the sensitisation hazard class: sum Cat. 1/1B sensitisers (Cat. 1A counts 10×) against the classification cut-off. ≥1.0% (Cat. 1/1B) or ≥0.1% (Cat. 1A) means the candle is H317-classified. Below those cut-offs, any single sensitiser still ≥0.1% (Cat. 1/1B), ≥0.01% (Cat. 1A) or one-tenth of an SCL must be named in an EUH208 statement.
Worked example A — EUH208 only:
- Fragrance oil contains Linalool at 5% (SDS Section 3; Linalool is classified Skin Sens. 1B)
- Your candle uses this oil at a 10% fragrance load
- Calculation: 5% × 10% = 0.5% Linalool in the finished candle
- 0.5% < 1.0% H317 cut-off, but ≥ 0.1% special-labelling threshold → EUH208 required (no H317)
- Label states: "Contains Linalool. May produce an allergic reaction."
Worked example B — full H317 classification:
- Oil contains Linalool at 18%, used at 10% load → 1.8% in the candle
- 1.8% ≥ 1.0% cut-off for a Cat. 1B sensitiser → the candle itself is classified H317: it carries the GHS07 pictogram, signal word and the H317/P-statements — not merely an EUH208 line.
- This is why a single “everything above 0.1% gets EUH208” shortcut is dangerous: at classification level the whole label changes.
What Happens If You Have Multiple Allergens?
If your candle contains several allergens above threshold, you must name all of them in the EUH208 statement:
"Contains Linalool, Limonene, Coumarin. May produce an allergic reaction."
The allergens are listed in order of decreasing concentration. There's no upper limit on how many you must name — if 8 allergens exceed threshold, all 8 appear on the label.
Common EUH208 Mistakes
❌ Using the fragrance oil's EUH208 statement directly
The oil's label reflects its own concentration (often 100% oil). Your candle is diluted — the allergen concentration in the final product is what matters. You may need fewer or more allergen names than the oil's label shows.
❌ Assuming "natural" oils don't trigger EUH208
Essential oils are complex chemical mixtures. Lavender essential oil naturally contains Linalool and Linalyl acetate. "Natural" doesn't mean allergen-free.
❌ Forgetting to recalculate when changing fragrance load
If you increase your fragrance load from 8% to 12%, allergens that were previously below threshold may now exceed it. Every formula change requires a recalculation.
❌ Not reacting to a revised classification
What triggers EUH208 is a component's classification, not a fixed list — so keep the CLP Annex VI / GB MCL entries and your supplier's current SDS under review. An ATP, a GB MCL update, or a new SDS revision can add a sensitiser classification even though your formula hasn't changed.
Where Does EUH208 Go on the Label?
EUH208 is placed within the hazard statement section of the CLP label. It appears alongside H-statements and P-statements, typically near the bottom of the label text block. The names must be the chemical names used in CLP Annex VI / the GB MCL list or the supplier's SDS (e.g. “Linalool”, “(R)-p-mentha-1,8-diene” for d-limonene) — trade names (“fresh citrus blend”) and plant descriptions (“lavender extract”) are not sufficient. (INCI names are a cosmetics-labelling convention, not the CLP standard.)
Not sure which allergens your candle contains?
Send us your fragrance oil SDS and load and we'll tell you free exactly which allergens trigger EUH208 on your current label — no obligation. A corrected, print-ready label is £39 per fragrance, delivered in 48 hours.
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