CLP's Explained Blog Post by Half a Melon

The safest Risk is the one you didn't take!

Every week we receive dozens of emails and messages from customer's requesting more information, help and advise on CLP's.  Today we are going to cover the Advanced Information for the more experienced Makers as well as going over the Basics for our Beginners. 

Half a Melon is a Certified CLP Supplier since January 2021.

The Basics

  • What is a CLP Label?
  • Why you should be downloading your SDS and CLP information and keeping it.
  • The difference between a Warning Label and a CLP Label.
  • Size really does matter!
  • What information should be contained in a CLP Label and why.
  • Where should a CLP Label be placed.

Advanced

  • Diffusers & Room Sprays
  • Different percentages
  • Why you should be Testing different percentages and bases
  • What bases are classed as Hazardous
  • What bases are classed as Non Hazardous
  • Why you will need to have your CLP recalculated if you are using Perfumers Alcohol
  • CLP's for Candles and why they are different to Wax Melts

The Basic CLP Information

Classification, Labelling & Packaging otherwise known as a CLP.

 

This is a Government Regulation that covers all hazardous substances and has been in place since 2009 (amended in 2015).   From the 1st January 2021 this now forms part of the GB CLP Regulation.  

You have a legal duty to understand your obligations and duties under the GB CLP Regulation. 

 CLP guidance explains hazard symbols, pictograms, hazard wording and safety advice.

The regulations state that certain information must be supplied on all CLP labels along with detailing specific requirements on shape and size of the information provided:

 

Downloading and Saving SDS sheets and CLP's

Each Scent/ Fragrance Oil will be different as they will contain different ingredients,  different ratio's and different allergen information.

You are REQUIRED by Trading Standards to Download the SDS sheet & CLP for every single Fragrance Oil you purchase and you should create a digital folder or print them out and place in a folder/binder so that if TS ever ask to see the documents you have them to hand.  Your business is NOT compliant if you do not do this. 

 Always check the CLP every time you purchase a new batch of FO as sometimes suppliers change manufacturer's so the CLP may be different.

Also worth noting that you may find the same Fragrance Oil being sold by different suppliers but it may be from a different manufacturer so you can ONLY use the CLP from the supplier you purchased from. If you purchase Fragrance Oil of the same name from a different supplier you MUST download their data and use their CLP.


If you purchase Fragrance Oils as part of a destash then the seller of these oils should be emailing you the SDS and CLP info. If they cannot do this then we advise not to purchase as the Oils maybe discontinued which means you will not be able to get the correct information or the Oils could be old and the supplier may now use a different manufacturer and their current SDS and CLP may be different from the one for the destached Oils. Plus, if you do not have the SDS and CLP info then your products will be non compliant.

Size Really Does Matter!

 

All Pictograms must be contained in a red square and a white background positioned as a diamond shape. This square MUST be 1cm squared in size.

Regulations also state that the text MUST be readable and therefore the Font size should be no smaller than size 4.

This means that your labels MUST be a certain size to meet these requirements:

 Circles - Minimum size 4.5cm (45mm) upwards

Squares - Minimum size 4.5cm (45mm) upwards

Rectangles  - Minimum size 5cm x 3cm (50mm x 30mm) upwards

Not all CLP's require a pictogram, a pictogram is only required if a Signal Word is triggered.

 The most common Trigger for this pictogram is:

'Warning'

A Trigger statement is:

' May cause an allergic skin reaction'.

The trigger word in this statement being the word 'skin'

This pictogram is not required when the statement is

' May cause an allergic reaction'


The trigger word for this pictogram is the word 'Toxic' so if you see the statement ' Toxic to aquatic life with long lasting effects' then this Pictogram must be present.
The word 'Harmful' does not trigger this pictogram.

 

The regulations state that certain information must be supplied on all CLP labels:

  • Product Identifies
  • Hazard Pictograms where applicable
  • Hazard statements
  • Allergen information
  • Signal Words
  • Precautionary statements
  • Contact details

Your Name or Business name, house number & postcode and an active contact number for yourself MUST be included in all of your CLP's. This is because the items that you are making & selling could cause an allergic reaction or may be harmful in some way so it is important that a customer or Trading Standards can contact you directly either my telephone or in writing for a full disclosure of the SDS information.

You cannot swap the telephone number for an email address, it MUST be an Active telephone number registered to yourself or your business.

CLP Label Placement

Each product must have it's own CLP and each scent must have it's own CLP.

For a Candle the CLP must be attached to the vessel (Glass or tin) that the candle is contained in.

For Wax Melts this should be attached to the cellophane packaging on the back.

Home Bargain boxes - each section containing a different scent/FO MUST have it's own CLP and ALL of the above information if applicable must be included in the CLP. So if you have 8 cells in the box and use 2 cells per scent then you are required to have 4 CLP's. If each of the 8 cells has a different scent then you are required to have 8 separate CLP's. If a customer experienced a reaction to one particular scent and it needed to be sent for testing then the specific CLP would also be required which is why it must be a separate label and contain ALL of the required information.

 

Advanced CLP information

About 70% of the emails and messages we receive about CLP's are for Diffuser and Room Spray Products. The most common question we get asked is "Can you make me CLP's for Reed Diffusers?"


Typically Reed Diffuser's are made with one of 3 bases 'Augeo' or 'Perfumer's Alcohol' or 'Dowanol DPM'. The Fragrance Oil of your choice is mixed with one of these bases to create the Diffuser.

For Room Sprays the bases tend to be 'Cyclomethicone' or 'Perfumer's Alcohol' or 'Augeo'

For both of these products the recipes tend to recommend anything from 12% to 25% Fragrance Oil.
This means you cannot use the same CLP that you would use for Wax Melts, Candles, Sizzlers or Carpet Freshener as these are up to and including 10% maximum Fragrance Oil load.

So you will need what we call a 25% CLP - This means you can use this CLP if you are using 10.01% up to 25%, so if you only use 15% FO in your product then this is still the correct CLP.

Hazardous and Non Hazardous Bases

Testing to be compliant

When you take two products and mix them together to make an entirely new product you become the manufacturer. It is the manufacturers responsibility to ensure that their new product is safe and compliant. Even if you are making your products at home on a very small scale you are still a manufacturer. To ensure your product is compliant you should be following the recipes (you should have these downloaded and stored either digitally or paper copy with your SDS and CLP information). And you should be using the correct CLP label.

If you are using more than 10% Fragrance Oil in a Non Hazardous Base then you need a 25% CLP label that is logged/saved as 25% Non Hazardous. You cannot use a 25% Hazardous CLP or a 25% CLP that is labelled Augeo. It MUST be a 25% Non Hazardous CLP.

If you are using more than 10% Fragrance Oil with Augeo as your base you will need a 25% CLP marked as Hazardous or Augeo. You cannot use a 25% non hazardous CLP. (If the FO supplier does not state the base or if it is Hazardous or Non Hazardous, you MUST email them and ask them to confirm. The likelihood is that it will be a Non Hazardous base but you must check and save the email reply with your SDS and CLP information).

If you are using Phenoxyethonal as a base and more than 10% FO you will need a 25% Hazardous CLP.

If the correctly labelled CLP Label is not available on the website you purchased your Fragrance Oils (Under the SDS and CLP Downloads) then you cannot use this suppliers FO with these bases because the FO Supplier has NOT had their Oils tested with these bases using these percentages. This means that YOU, the manufacturer are responsible for ensuring that your product is compliant. This means you will need to pay for your SDS and CLP to be recalculated.
Perfumer's Alcohol

There are only 3 Fragrance Oil Suppliers in the UK that provide a CLP for Perfumer's Alcohol.
This means that these Fragrance Oil Suppliers have paid their manufacturer to test their oils with Perfumers Alcohol. The SDS and CLP has then been recalculated to reflect the additional risks and allergens and is available on the Suppliers website as a download.

These suppliers are:

Randalls Candles
Twilight Candle Co
TLLC
If you have purchased your Fragrance Oils from any other supplier you CANNOT use them with Perfumer's Alcohol. The only way you can do this is to pay for the SDS and CLP to be recalculated.

What Does Recalculating a CLP mean?

To be able to recalculate an SDS and CLP you need to have background in Chemistry or Pharmaceuticals. Recalculation involves recalculating how the Fragrance Oil reacts with different bases and at different percentages and producing the new risks and allergens. This is also known as Testing. Specialist software that costs thousands of pounds and extensive training is required to be able to recalculate an SDS and CLP. As such this service is no readily available and is also very expensive.

Half a Melon recommends Lyssium Fragance Oils for this service.
They charge £20 + VAT per scent/per base.

In reality it is actually a cheaper option to re-purchase your Fragrance Oils from a Fragrance Oil Supplier that has invested in having their Oils tested with various different bases and different percentages.

Why a Candle CLP is Different to a Wax Melt CLP
Regulations state that a Candle CLP Label MUST have 3 specific Warning Icons included and MUST have a Warning Explanation Yellow Triangle present.

These icons/symbols are in addition to any required Pictograms. As such this means that a Candle CLP Label needs to be a certain size to allow for all of this information to be present and at the correct sizing.
4.5cm (45mm) is the smallest size label a Candle CLP can be produced on.
Regulations also state that you MUST include the written Warning Text and Usage information with your sale.

You do NOT have to this information on the Candle Vessel (glass or tin) but it does need to be included with the product.

You can (optional) include on your CLP label but because this is additional information you will need a bigger label. 6.5cm (65mm) is the smallest label available for a Combined Candle CLP and Warning Label

IFRA - The 49th Amendment

This will be effective from the 1st May 2022.
At the moment the classification for Diffusers is set quite high meaning that many Fragrance Oils can have a maximum load of up to 33.33% (although here in the UK the max you can use is 25% as this is the largest CLP percentage label available).

In May 2022 this is set to change and the maximum FO load is set to be lowered dramatically as testing carried out by ECHA and HSE has shown that many Fragrance Oils do not react well with certain bases in higher percentages and as such the classifications have been changed. You may have already noticed that your favourite Fragrance no longer has a 25% CLP available when it used to, this is the reason why, as suppliers start to ensure that they are correctly regulated in accordance with new classifications.

Why PDF's/ Ready Made Downloads are NOT recommended

You know you have your favourite Fragrance Oil Supplier and that is your Go To for all of your Oils.... But you have just had a massive run on a particular scent and you have run out and need to order some more ASAP.... But your normal supplier is Sold Out and you have orders that need to go out this week... You can't wait so you do some Googling and you find another Oil Supplier that you haven't used before but they have the fragrance Oil you need in stock and it can be with you tomorrow... So you place your order.

Now you know, that you need to use the new suppliers CLP (and if you didn't know this, then you do now) !! Why? Because, you have no way of knowing if it came from the same manufacturer as your other supplier.

Well this is the same for your Oil Suppliers, they have had a massive run on a particular scent and their normal manufacturer where they get their Oils from has Sold Out, so they go to a different manufacturer. They don't put on the website that it is from somewhere else, they just upload the stock to the inventory and change the SDS and CLP info.

And these are the TWO reasons you should NOT be using a Downloaded PDF for your CLP's. Because they CHANGE and you could be non compliant and not even know it!!

If you are using 3.7cm (37mm) or smaller CLPs - You are non compliant

Some Fragrance Oils don't have a lot of information, they have barely any ingredients, they don't have any allergen triggers and no pictograms - These CLP's can be on 3.7cm (37mm) or smaller labels and they will be compliant.

However, the majority of Fragrance Oils have trigger warnings and pictograms along with a lot of text information, it is these CLP labels that are non compliant on a 3.7cm (37mm) label as the font size and the pictograms cannot be the required sizes and fit on this size label.

CLP's are complicated enough as it is without then having to remember which CLP you can have at which size and still be compliant, plus, from a cosmetic point of view it is nice to have all of your labels a uniform size. We touched on this earlier but wanted to come back to it because we know that there are still many CLP suppliers using 3.7cm (37mm) labels.

Essential Oils

If you would like to use Essential Oils with your wax, diffuser or room spray products they still require a CLP and the majority of Essential Oil Suppliers do NOT offer this service which means you will need to pay for a recalculation.

The safest RISK is the one you didn’t take - Never Take a Risk with Compliance - Always CLP it !!


We hope this information has been useful, please save it for future reference. At Half a Melon we pride ourselves in only offering/selling products that are 100% compliant. We also genuinely care about you and your business and want to ensure that you and your business is also 100% compliant.

We are always happy to share our knowledge, advise and support you when it comes to CLP's - Because Sharing is Caring ❤
You can purchase your CLP's here
Lauren & Sharon xx