At first glance, candles may not seem like chemicals — but under European legislation, they are. If you manufacture or import scented candles or wax melts, you must comply with the legal obligations that apply to this type of mixture under the REACH and CLP Regulations before placing them on the market.
When is a candle considered hazardous?
Candles are primarily made of waxes, which are generally not classified as hazardous. However, if they contain fragrances, dyes, or other additives, these substances may render the final product a hazardous mixture. For example:
- Many fragrances are sensitisers (they may cause allergic reactions).
- Some dyes may have irritant effects or be harmful to the environment.
To determine whether your candle falls into this category, you must assess its hazard classification according to the criteria set out in the CLP Regulation, based on the properties of its components.
What if my candle is classified as hazardous?
If your candle is classified as hazardous, or it contains hazardous ingredients above specific concentration thresholds:
- It must be labelled in accordance with CLP requirements (e.g., with hazard statements such as “may cause an allergic skin reaction”).
- It must be packaged appropriately under the CLP criteria.
Simply placing a label on glass or paper packaging is not always sufficient. Labelling and packaging must both comply with CLP provisions.
In addition, if your product is classified as hazardous based on its physical hazards or health effects:
- You must submit a Poison Centre Notification (PCN) in each Member State where the product is placed on the market.
- A Unique Formula Identifier (UFI) code must appear on the product label.
What other legal obligations apply?
Other requirements that may apply (non-exhaustive list):
- A Safety Data Sheet (SDS) is mandatory if you supply your products to professional users (e.g., restaurants).
- You must notify the Classification and Labelling Inventory for all substances imported from outside the EU.
- A candle is a combination of a mixture (wax) and an article (wick), so if it contains any Substance of Very High Concern (SVHC) above 0.1%, you must submit a SCIP notification to the ECHA database.
What about REACH registration?
If you manufacture candles in the EU using ingredients sourced from EU suppliers, you are not required to register substances under REACH.
However, if you import substances directly from outside the EU and exceed 1 tonne per year, you may be required to register them under REACH.
Not sure if your candle requires specific labelling? Uncertain whether you need to notify the SCIP database or the Poison Centre?
At ServiREACH, we help you:
- Assess whether your candle qualifies as a hazardous mixture.
- Draft or review your Safety Data Sheets.
- Manage your UFI, submit required notifications, and assist with CLP-compliant labelling.
- Ensure your product complies with REACH obligations.