What is a CLP label and why do we need it?
CLP stands for "Classification, Labelling and Packaging". The CLP label communicates to the user of the product the main hazards and state appropriate safety precautions. CLP label is aimed at workers, consumers and general public and it is linked to SDS section 2.2.
Scented candles and Reed Diffusers are considered to be a chemical mixtures and therefore, according to CLP regulation, needs to be classified for any potential hazards. This duties applies to any manufacturer of chemical products, irrespectively of the scale of production.
Who needs to place a CLP label on their products?
Anyone who place a hazardous product on the market is responsible for labelling their products. Scented products with hazardous properties must not be placed on the market unless they comply with CLP regulations.
What does it mean to place on the market? As its defined in EU CLP regulation: "to make a substance or mixture available to third party" That means;
Selling to customers
giving away your products (eg. samples)
In some cases there is no need for a CLP label, for e.g. if the mixture contains hazardous components under specified concentrations limits. This has to be determined separately for each scented products formulations as they are all made up from different components.
The following content needs to appear on CLP label
Product identifiers - Name and composition information.
For mixtures, the product identifier will be the name of the finished product. The name on the label must match name on Safety Data Sheet. The composition information must include names of the components driving the classification for certain Hazard Classes.
There are three categories of signal words: danger, warning or blank (applies to mixtures with lower hazard classification).
Hazard statement provides you with the specific information on what the hazard is.
Acts as a visual representation of hazard. It must be no smaller than 1 square cm measured along the side of the pictogram. The Hazard statements are represented by pictograms. Some hazards do not require hazard pictograms, e.g. lower level environmental hazards.
The classification is supplemented with precautionary statements for guidance on safe handling. e.g. P102 Keep out of reach of children. The precautionary statements should be selected to those most relevant and important and there shouldn't be more the 6 p-statements on the label.
Can include: EUH statements, UFI code and any other information, e.g. batch codes.
Very often scented products are supplemented with EUH208 statement 'Contains (name of sensitising substance). May produce an allergic reaction'. The threshold for the substance to trigger EUH208 statement is very low (≥0.1%), therefore a number of common fragrances are classified as sensitisers.
Supplier Details (address and phone number)
Tells you who is responsible for placing the product on the market. If the hazardous product is placed on EU market, the EU address must be placed on the label.
Application of labels
The label must be firmly affixed to the packaging and must be readable horizontally when the package is set down normally. Where the package is a combination of inner and outer (e.g. candle in box), CLP label must be placed on both inner and outer package.
If the package is of a shape where a label can't be applied, a tie on tag, fold out label or label on the outer package can be used.
Updating your labels
Manufacturers of candles, reed diffusers and other scented products are required to classify and, if mixture triggers hazard statements, label them in accordance with the requirements of the CLP regulation. It's their responsibility to make themselves aware of any updates that may affect their classification and any updates must be made without delay.
The information about the mixture must be kept and available for at least 10 years after it was placed on the market.