When the UK left the EU, the CLP Regulation (EC) No 1272/2008 was copied into retained UK law as "UK CLP" โ now commonly called GB CLP. On the surface, the two systems look identical. But since 2021, they've been drifting apart. And for UK candle makers who sell into the EU โ or EU makers who sell into the UK โ that divergence creates real compliance risk.
This guide breaks down exactly where GB CLP and EU CLP differ today, and what you need to do to sell legally in both markets.
The Short Version
GB CLP and EU CLP started from the same base text. But the UK's Health and Safety Executive (HSE) and the EU's European Chemicals Agency (ECHA) now update their respective regulations independently. That means:
- Hazard classifications may differ for the same substance
- Labelling requirements are updated on different timelines
- Certain administrative requirements have been removed in GB (e.g., UFI and the GB notification database)
- The EU is adding new hazard classes that GB hasn't adopted yet
Key Differences: GB CLP vs EU CLP in 2026
| Aspect | GB CLP (HSE) | EU CLP (ECHA) |
|---|---|---|
| Regulator | Health and Safety Executive (HSE) | European Chemicals Agency (ECHA) |
| Base regulation | Retained EU CLP + UK amendments (incl. SI 2020/1577 and SI 2026/484) | EU CLP (EC) No 1272/2008 + ATP amendments |
| UFI / Poison Centre (Annex VIII) | โ Revoked for GB by end-2023; a GB-only pack carries no UFI | โ Required for consumer & professional mixtures (NI follows EU) |
| GB notification database (C&L) | โ Removed under SI 2026/484 (May 2026) | EU C&L Inventory notification still applies to EU suppliers |
| New hazard classes (Reg. 2023/707) | โ Not adopted into GB CLP (no UN GHS consensus) | โ Adopted on the EU timeline |
| EUH208 trigger | Same rule under both regimes: no fixed allergen list โ thresholds follow each component's sensitiser classification (โฅ0.1% Cat. 1/1B, โฅ0.01% Cat. 1A) | |
| Poison centre notification | โ Not required | โ Required (via ECHA portal) |
| Label language | English | Official language(s) of each member state |
| Supplier on label | UK-based supplier required | EU-based importer required |
What Changed for GB CLP Post-Brexit
UFI & Poison Centre Notification โ Not for GB-Only Packs
The Unique Formula Identifier (UFI) is part of the EU's CLP Annex VIII poison-centre regime; its consumer-mixture deadline was 1 January 2021 in the EU. Great Britain never adopted the harmonised PCN format and revoked Annex VIII from GB CLP at the end of 2023. A GB-only candle therefore carries no UFI and needs no poison-centre notification. Products sold into the EU or Northern Ireland still need a UFI and an ECHA portal notification โ the responsibility sits with the EU-based importer/downstream user.
C&L Inventory โ GB Notification Database Removed
Under EU CLP, EU importers and manufacturers still submit classification notifications to the ECHA C&L Inventory. GB's separate notification database was removed by SI 2026 No. 484 (made April 2026, in force May 2026); the GB Mandatory Classification and Labelling (MCL) list โ GB's analogue of Annex VI โ remains in force and is updated independently by HSE.
SI 2026/484 โ The Latest GB CLP Amendment
The Chemicals (Health and Safety) (Amendment, Consequential and Transitional Provision) Regulations 2026 No. 484 made housekeeping changes to GB CLP, chiefly removing the GB notification database and certain technical notes. It did not change candle labelling duties, hazard statements or sensitiser thresholds. Note that โSI 2026/23โ is a separate cosmetics instrument and does not amend CLP โ the two regimes are often confused online.
What's Changing in EU CLP
ATP Updates โ and a Common Cosmetics Mix-Up
The EU updates CLP through Adaptations to Technical Progress (ATPs), which revise Annex VI classifications and can therefore change how a candle classifies. Separately, Commission Regulation (EU) 2023/1545 expanded the cosmetics fragrance-declaration list beyond the original 26 substances, with 0.01% rinse-off / 0.001% leave-on disclosure thresholds. That rule belongs to the Cosmetics Regulation (EC) No 1223/2009 โ it does not apply to candles, and CLP never uses a wash-off/leave-on split for them. Candle EUH208 duties follow each component's CLP sensitiser classification as described above.
New Hazard Classes
The EU is progressively adopting GHS Revision 7 and 8 changes, including new hazard classes for endocrine disruptors and updated criteria for existing classes. These changes are being phased in through Adaptation to Technical Progress (ATP) regulations.
What This Means for UK Candle Makers
If You Sell Only in Great Britain
You follow GB CLP only. Your label needs:
- UK-based supplier details
- Classification per GB CLP rules
- No UFI code needed
- No poison centre notification
- EUH208 handled per the component's sensitiser classification โ no UFI, no poison-centre step
If You Sell in the EU (Including Northern Ireland)
You follow EU CLP. Additionally:
- You need an EU-based importer whose details appear on the label
- UFI codes are required
- Poison centre notifications must be filed
- Labels must be in the official language(s) of each member state you sell into
- C&L inventory notification is required
If You Sell in Both
You need dual compliance. Practically, this means:
- Two separate CLP assessments (one GB, one EU)
- Two versions of the label (or a combined label that meets both requirements)
- UK supplier details for GB; EU importer details for EU/NI
- UFI for EU; no UFI needed for GB-only
Can You Use One Label for Both?
It's possible to create a single label that satisfies both regimes by including the most stringent requirements from each. But there are practical limits:
- The supplier details conflict (UK address for GB vs. EU importer for EU) โ you'd need separate labels or a dual-address approach
- Language requirements differ (English-only for GB vs. local languages for EU member states)
- UFI adds complexity for a GB-only product
For most small candle makers, the cleanest approach is two separate labels โ one for GB, one for EU โ each generated from the respective regulatory assessment.
How PixHarvest Handles Dual Compliance
When you order a CLP label from PixHarvest, we can provide:
- GB-only label โ optimised for Great Britain market, no UFI
- EU-only label โ full EU CLP compliance with UFI support
- Dual pack โ both labels from a single assessment, saving time and ensuring consistency
Every label is reviewed by a human compliance specialist who checks the classification against both HSE and ECHA requirements.
Not Sure Which Regime Applies to You?
Send us your current label or SDS and we'll review your GB/EU position free, with no obligation. If you need a corrected or print-ready label, it's ยฃ39 per fragrance in 48 hours โ or a dual GB + EU pack from a single assessment.