EU Candle Labeling Requirements for Private-Label Brands

Selling candles in the European Union requires compliance with multiple overlapping regulations. For private-label brands sourcing from OEM factories outside the EU, label compliance is the brand owner’s legal responsibility. Incorrect labeling is the single most common reason for customs detention of candle shipments entering the EU. This guide covers what must appear on your labels and why.

The Regulatory Framework

Candle labeling in the EU is governed by three primary regulations:

1. CLP Regulation (EC 1272/2008): Classification, Labelling and Packaging of substances and mixtures. Applies because scented candles contain fragrance chemicals classified as hazardous mixtures.
2. GPSR (EU 2023/988): General Product Safety Regulation, effective December 2024. Covers traceability, responsible person requirements, and general safety information.
3. EN 15494: Product labeling standard specific to candles, covering fire safety warnings.

All three apply simultaneously to a single scented candle product.

CLP Labeling: Pictograms and Hazard Statements

Scented candles are classified as hazardous mixtures under CLP because they contain fragrance allergens and potentially sensitizing chemicals. The label must include:

Required Pictograms

Most scented candles require the GHS07 exclamation mark pictogram (white diamond with red border, black exclamation mark). Depending on the specific fragrance composition, additional pictograms may be required:

• GHS07 (Exclamation mark): Skin sensitization, eye irritation, aquatic toxicity (most common)
• GHS09 (Environment/dead tree and fish): Aquatic chronic toxicity, if fragrance contains substances toxic to aquatic life above threshold concentrations
• GHS08 (Health hazard/silhouette): Aspiration hazard, if the candle contains certain hydrocarbon-based ingredients above 10 percent

The pictogram must be printed at minimum 1 cm x 1 cm (for packages under 3 liters) or proportionally larger for bigger packaging.

Signal Words and Hazard Statements

Based on classification, the label must carry:

• Signal word: “Warning” (for Category 2/3 hazards) or “Danger” (for Category 1 hazards). Most scented candles use “Warning.”
• H-statements: For example, H317 “May cause an allergic skin reaction,” H412 “Harmful to aquatic life with long lasting effects.”
• P-statements: Prevention and response statements, such as P102 “Keep out of reach of children,” P273 “Avoid release to the environment,” P501 “Dispose of contents/container in accordance with local regulations.”

The EUH208 Statement

If the fragrance contains any of the 26 declared allergens (now expanded to 80+ under recent amendments) above 0.01 percent in the mixture, the label must include: “EUH208: Contains [allergen name]. May produce an allergic reaction.”

Common allergens in candle fragrances requiring disclosure:

• Linalool (found in lavender, bergamot, citrus blends)
• Limonene (citrus fragrances)
• Citronellol (rose, geranium notes)
• Geraniol (floral compositions)
• Coumarin (vanilla, tonka, gourmand bases)
• Hexyl cinnamal (jasmine, floral accords)

Your fragrance supplier must provide a CLP-compliant safety data sheet (SDS) listing all classified components. Your OEM factory or a regulatory consultant uses this SDS to determine the final product classification and label content.

UFI Codes: Mandatory Since January 2025

The Unique Formula Identifier (UFI) is a 16-character alphanumeric code that links your product to its exact formulation in the EU Poison Centre Notification (PCN) system.

Requirements:

• Every scented candle sold in the EU must have a UFI printed on the label.
• The UFI must be preceded by the label “UFI:” in capital letters.
• It must be placed near the hazard pictograms or in a clearly visible location on the packaging.
• The UFI is generated from your VAT number and an internal product formula code via the ECHA UFI generator tool (free, online).

Poison Centre Notification: Before placing a product on the EU market, you must submit a PCN dossier via the ECHA Submission Portal. This dossier includes:

• Product composition (fragrance components with concentration ranges)
• CLP classification
• Toxicological information
• UFI code

Notification must be completed in each EU member state where the product is sold, though the centralized ECHA portal simplifies multi-country submission. Allow 2-4 weeks for processing.

Fire Safety Labeling (EN 15494)

In addition to CLP content, the label must carry fire safety information:

• The general warning symbol (flame in triangle or ISO 7010 W001)
• Safety instructions in the language(s) of the destination country
• “Never leave a burning candle unattended”
• “Keep away from children and pets”
• “Burn on a heat-resistant surface”
• “Trim wick to 5mm before lighting”
• “Do not burn for more than 4 hours”
• “Discontinue use when 10mm of wax remains”

Multi-language labels are common for pan-EU distribution. A single label can carry text in multiple languages if all required content is legible.

GPSR Traceability Requirements

Under GPSR (effective December 2024), every candle label must also include:

• Manufacturer name and address (or the private-label brand’s registered EU address)
• EU Responsible Person: For non-EU manufacturers, the name and address of the appointed EU authorized representative
• Product identifier: Type, batch, serial, or model number for traceability
• Country of origin (e.g., “Made in China”)

Practical Label Layout

A compliant EU candle label typically includes, from top to bottom:

1. Brand name and product name
2. CLP pictogram(s) with signal word
3. H-statements and P-statements
4. EUH208 allergen statement
5. UFI code
6. Fire safety warnings and pictogram
7. Manufacturer/importer details and EU responsible person
8. Batch number and country of origin
9. Net weight/volume
10. Burn time estimate (optional but expected by retailers)

Minimum label area for a standard 200g container candle is approximately 80mm x 120mm to accommodate all required elements legibly at minimum font sizes.

Working with Your OEM Factory

Your factory should provide:

• Fragrance SDS documentation for each scent variant
• CLP classification support or referral to a regulatory service
• Label template with correct pictogram placement
• Batch coding on each unit

However, the legal obligation for correct labeling rests with the brand owner or EU importer. Budget for a regulatory review of your final label artwork before printing. Services specializing in EU chemical compliance typically charge 200-500 euros per SKU for a label review.

At Aromiso, we provide complete CLP documentation packages with every fragrance formulation, including allergen declarations and recommended label text, to streamline our buyers’ compliance process.