Here's a scenario we see constantly: a candle maker buys a fragrance oil. The supplier sends the oil with a CLP label. The maker copies that label โ or a version of it โ onto their finished candle. Done, right?
Wrong. And potentially dangerously wrong.
The CLP label on your fragrance oil describes the hazards of the pure, undiluted oil. Your candle contains that oil at, say, 6-10% concentration. At that dilution, the hazard profile is completely different. Using the supplier's label is like putting a "High Voltage" warning on a AA battery โ technically there's a voltage, but the classification is for a completely different product.
The Science: Concentration Determines Classification
CLP classification follows the additivity method. For each hazardous component in a mixture, you calculate its effective concentration in the final product and compare it against cut-off values:
Example Calculation
Fragrance oil SDS (Section 3) says:
Linalool โ 5% of the fragrance oil
Limonene โ 3% of the fragrance oil
Your candle uses 8% fragrance load:
Linalool in the candle = 5% ร 0.08 = 0.4%
Limonene in the candle = 3% ร 0.08 = 0.24%
CLP cut-off for Skin Sensitiser Category 1: 1.0%
EUH208 special-labelling threshold: 0.1% (Cat. 1/1B sensitisers) or 0.01% (Cat. 1A); below the 1.0% H317 classification cut-off
Result: Linalool at 0.4% is below the Skin Sensitiser Cat. 1 threshold of 1.0% โ so that hazard class may not apply to your candle. But at 0.4%, it's well above the EUH208 disclosure threshold, so you must name it on the label.
This is fundamentally different from the supplier's label, where Linalool at 5% does trigger the Skin Sensitiser classification. The hazards change with concentration. The label must reflect the final product, not the raw material.
5 Common Mistakes Suppliers' Labels Get Wrong for Your Candle
1. Wrong Hazard Classification
As shown above, the pure oil may classify as a skin sensitiser (Cat. 1) while your diluted candle may not. Conversely, if you use a higher fragrance load than the supplier assumed, you might need additional hazard classes that the supplier's label doesn't include.
2. Wrong Signal Word
The supplier's oil might carry "Danger" due to high concentrations. Your candle at 6% load might only warrant "Warning" โ or vice versa if the supplier underestimated the concentration.
3. Missing or Extra H/P Statements
Different classifications trigger different H and P statements. A label designed for the oil will have statements that don't apply to your candle, and may be missing statements that do.
4. Wrong EUH208 Allergen List
The allergens that need to be disclosed depend on the concentration in the final product. The supplier's label names allergens for their oil โ not for your candle at your specific load.
5. Wrong or Missing Supplier Details
The supplier's label shows their business details. Your candle label must show your business name, address, and phone number as the supplier of the finished product. This is non-negotiable under CLP.
The Legal Reality: You Are the "Downstream User"
Under CLP law, when you blend fragrance oil into wax to make a candle, you become a "downstream user" โ and you take on the legal obligation to classify, label, and package the resulting mixture.
The HSE has stated publicly that they expect candle makers to perform their own classification based on the SDS provided by their fragrance supplier, combined with knowledge of their own formulation parameters.
The Hidden Cost of "Free" Labels
Some fragrance suppliers offer "free CLP labels" as a value-add. These are typically generated for the oil itself, not for your finished candle. Here's the real cost if you use them incorrectly:
| Risk | Consequence |
|---|---|
| Incorrect classification | Trading Standards enforcement, product recall |
| Missing allergen disclosure | Consumer allergic reaction โ liability claim |
| Wrong supplier details | Label doesn't identify you โ non-compliant by default |
| HSE inspection finds errors | Improvement notice, potential prosecution |
| Retailer demands documentation | Unable to provide your own classification โ lost wholesale account |
A professional CLP label for a single fragrance costs less than a takeaway meal. The cost of getting it wrong โ a product recall, a prosecution, or an allergic reaction โ is orders of magnitude higher.
What a Professional CLP Service Does Differently
When PixHarvest prepares your CLP label, we:
- Read your fragrance oil's SDS โ specifically Section 3, which lists each component and its concentration
- Apply your fragrance load โ we multiply each component's concentration by your actual load percentage
- Classify from scratch โ using the additivity method, we determine the correct classification for YOUR candle
- Generate the correct label โ pictograms, signal word, H/P statements, and EUH208 allergens based on YOUR product
- Human review โ every label is checked by a compliance specialist against current HSE and ECHA requirements
- Include your details โ your business name, address, and phone number as the supplier
The result is a label that's legally compliant for your specific product, not a generic label designed for a different product at a different concentration.
Get a Free Review of What Your Supplier Gave You
Forward the supplier label or SDS and we'll check it free against your fragrance, load and product โ and tell you the exact gaps, with no obligation. If you need a corrected, print-ready CLP label built on your own data, it's ยฃ39 per fragrance with a 48-hour human review.
What If My Supplier Refuses to Share the Full SDS?
You're entitled to receive a Safety Data Sheet with any hazardous substance you purchase. If your supplier won't provide Section 3 (composition), you cannot accurately classify your product โ which means you cannot legally label it.
In practice:
- Contact your supplier and request the full SDS including Section 3
- If they refuse, consider switching to a transparent supplier
- UK suppliers like Candle Shack, Supplies for Candles, and The Soapery provide full SDS documentation with every order
The Bottom Line
Your candle is a different product from your fragrance oil. It has a different concentration, different hazards, and therefore requires a different label. Using the supplier's CLP label isn't just technically incorrect โ it's a legal liability.
The good news? Getting it right is straightforward and affordable. You just need someone who knows the rules and is willing to do the calculation properly.