CLP Labels for Wax Melts vs Candles: What's Different?
You make both scented candles and wax melts. Same wax, same fragrance oil, same supplier. Surely the CLP label is the same, right? Wrong.
Both products fall under CLP Regulation (EC) No 1272/2008, but the classification outcome — and therefore the label — can differ significantly. Here's exactly what changes and why it matters.
The Core Difference: How the Product Is Used
CLP classification depends on exposure route. Candles and wax melts expose users to fragrance compounds differently:
🕯 Candles
Fragrance is released through combustion. Compounds enter the air via burning wax and are inhaled. The heat also changes the chemical profile — some compounds decompose, others form new byproducts.
🫙 Wax Melts
Fragrance is released through low-temperature evaporation (typically 55–65°C in a warmer). No combustion occurs. The chemical profile is closer to the raw fragrance oil, meaning allergen concentrations can be higher in the vapour.
This difference affects the classification calculation, particularly for inhalation hazards and skin sensitisation thresholds.
What Stays the Same
Both candles and wax melts share these CLP requirements:
- Classification under the same regulation (CLP / GB CLP)
- Same additive method for calculating hazard from SDS data
- Same GHS pictogram requirements (GHS07, GHS09)
- Same EUH208 allergen naming rules
- Same supplier identity requirements (name, address, phone)
- Same signal word logic ("Warning" or "Danger")
What Actually Differs
| Element | Candles | Wax Melts |
|---|---|---|
| Fragrance load (typical) | 6–12% of total wax weight | 10–15% (higher concentration) |
| Exposure route | Inhalation of combustion products | Inhalation of heated vapour + potential skin contact |
| Fire safety label | BS EN 15494 required | Not required (no open flame) |
| Net weight marking | Yes (pre-packaged product) | Yes (pre-packaged product) |
| EUH208 allergen threshold | Standard CLP thresholds | Same thresholds, but higher load = more likely to trigger |
| P-statements | Includes "burn within sight" type warnings | Focuses on skin contact and "keep out of reach of children" |
The Fragrance Load Factor
This is where most makers get caught out. Wax melts typically use a higher fragrance load than candles (10–15% vs 6–12%). That means:
- Higher concentration of allergens in the final product
- More likely to exceed the 0.1% EUH208 threshold
- May trigger additional hazard classifications that the candle version doesn't have
Example: A fragrance oil containing Limonene at 20%:
- In a candle at 8% load: 20% × 8% = 1.6% Limonene → above 1% threshold → classified
- In a wax melt at 12% load: 20% × 12% = 2.4% Limonene → well above threshold → same classification, but higher concentration means stricter P-statements may apply
The Fire Safety Label Difference
This is the most visible difference on the packaging:
- Candles: Must carry a BS EN 15494 fire safety label with pictograms and text warnings about burning within sight, keeping away from draughts, and maximum burn time.
- Wax melts: No fire safety label required. However, safe-use instructions (e.g., "Use only with a tea light warmer", "Don't leave unattended") are recommended for product liability reasons.
Can You Use One Label for Both?
No. Even if the fragrance oil is identical, the different fragrance loads, exposure routes, and fire safety requirements mean the labels must be separate. Using a candle label on a wax melt (or vice versa) is a compliance breach.
The rule is simple: one formulation = one label. If the product type, fragrance load, or wax type changes, the CLP classification must be recalculated and a new label produced.
What About Reed Diffusers and Room Sprays?
If you also make reed diffusers or room sprays, each of those is yet another distinct formulation requiring its own CLP assessment. Reed diffusers have different exposure dynamics (continuous passive evaporation) and room sprays involve pressurised dispensing — both affect the classification.
The good news: the calculation methodology is the same. You just need separate assessments for each product type.
Summary: The Key Differences at a Glance
- ✅ Same regulation, same classification method
- ⚠️ Different fragrance loads → different allergen concentrations
- ⚠️ Different exposure routes → potentially different hazard categories
- ⚠️ Different P-statements based on use pattern
- ❌ Candles need fire safety labels; wax melts don't
- ❌ You cannot share labels between product types
Making both candles and wax melts?
Each product type needs its own CLP label. Send us your current labels and we'll review them free across candles, melts, sprays and diffusers — no obligation. Corrected labels are £39 per fragrance in 48 hours.
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