Classification involves determining if a composition of a product triggers any health, environmental or physical hazard and labelling the product based on the results.
Candles are primarily made up of waxes which are in themselves non-hazardous and do not require classification. However, candles usually contain additives for fragrance and colour, some of which may be hazardous and if present at a high enough concentration, could require warning statements or pictograms.
The main cause for concern relates to sensitisation, where the presence of a particular substance at very low concentrations can trigger labelling requirements.
If a candle contains any sensitizing fragrance ingredient at more than 0.1%, the label should bear the statement:“Contains (name of fragrance/s). - May produce an allergic reaction.”
If a candle contains more than a total of 1% sensitizing fragrance ingredients, it should bear the exclamation point pictogram, the signal word WARNING, and have the statement: “May cause an allergic skin reaction” - and list some ingredients.
The greater the concentration of fragrance in the candle, the more likely it will trigger one or more of these warnings.
If the candle itself is not classified for sensitisation, there may still be a requirement to alert individuals who are already sensitised to the presence of a particular substance by including the special EU labelling phrase:
EUH208 'Contains (insert name of sensitising substance) - May produce an allergic reaction’.
This can apply where a sensitising ingredient is present at very low levels, that is, 0.1% for a subcategory 1B sensitiser or 0.01% for subcategory 1A. In some cases, for particularly potent sensitisers, it can be even lower – although these substances are not likely to be used in the candles.
On examining the information on the safety data sheet (SDS), it may be prudent to use a substitute product if possible.
Other health hazards
Other human health hazards, such as skin irritation, are unlikely to be required given what we know of the general composition of candles. However, this will need to be considered on a case-by-case basis by suppliers who know the full composition of the candle, the fragrances and the colourants.
Packaging containing a hazardous mixture must have a label firmly affixed to it immediately. The label must be easily readable horizontally when the package is set down normally.
Labels can be applied in alternative ways but only when it is not possible to apply the full label to the immediate packaging.
There are further exemptions to allow for certain information to be omitted from the label of particularly small packages.
It’s unlikely that a CLP label relating to flammability will be required for candles, as they are not likely to meet the classification for criterion for this to apply. However the danger of the open flame can be highlighted in the non-statutory pictograms which can be placed on labels.
An environmental classification may also be required in some cases, although this probably less likely.
The information to enable suppliers to determine classification should be available in the SDS provided by the suppliers of fragrances or colourants