CLP legisation – Classification, Labelling and Packaging
CLP legislation controls how and what you have to communicate about your products. For candle makers the most important thing about CLP is label design.
Brexit’s impact x candle making.
EU CLP – European Union | GB CLP – United Kingdom
Brexit didn’t impact many aspects of candle making. CLP legislation in UK has only few different aspects than EU CLP but if you want to sell candles in EU and UK you have to comply with both EU CLP and GB CLP.
CLP- compliant label has to include items from following list:
Supplier identification (the candle maker), Weight or mass of the candle, Product name or identifier, Hazard pictograms, Signal word, Hazard statements, Precautionary statements, Relevant supplementary informations, Unique formula identifier (UFI).
Label needs to be visible when the product is at rest in a normal position!
Label has to be in the language where the candle will be sold.
Also it is required to put on the label: Name, address, phone number of candle maker/authorised representative – Nominal quantity of candlel (weight of jar, wax, lid). – Product name – All substances in the mixture of the following nature: Acute toxicity, Skin corrosion, Serious eye damage, Germ cell mutagenicity, Carcinogenicity, Reproductive toxicity, Respiratory or skin sensitization, Specific target organ toxicity (STOT), Aspiration hazard.
In Safety Data Sheet you will find hazard pictograms, signal words (like WARNING), hazard statements, precautionary statements and relevant supplementary information (like additional hazard statements) which has to be included on the label.
UFI – unique formula identifier
The UFI is a 16-digit code used by Poison Centers to rapidly identify the contents of your candle in the event of an emergency.
UFIs are not required if you’re selling in the UK.
You can create your own UFI by using online tool provided by ECHA (European Chemicals Agency).
50th IFRA Standard Amendment.
We would like to remind you of the 50th IFRA Standards Amendment. The document assumes withdrawal of Mintlactone from list of fragrance ingredients.
The 50th amendment is effective from 30 August 2021 for newly introduced products and from 30 August 2022 for products that are currently on the market. The document directly concerns suppliers of raw materials, however, cosmetic manufacturers should contact their suppliers and verify that the new guidelines will not affect the need for changes in the formulation of products.
Changes should be of particular interest to manufacturers, who in the formulation of their cosmetics contain Mintlacotne. For more information, please read the IFRA documents.
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The use of Butylphenyl Methylpropional shall be prohibited in cosmetic products from 1st March 2022.
EU bans the use of a common fragrance ingredient: Butylphenyl Methylpropional (also known as BMHCA or Lilial).
European Commission Delegated Regulation (EU) 2020/1182 the 15th Adaptation to Technical Progress (ATP) of the Classification, Labelling and Packaging (CLP) Regulation, has been published in The Official Journal of the European Union on 11 August 2020.
The fragrance ingredient butylphenyl methylpropional (Lilial, BMHCA) was classified as toxic to reproduction (Repr. 1B – CMR 1B).
By default, the use of substances classified as CMR (carcinogenic, mutagenic or toxic to reproduction, under the CLP Regulation) is banned (European Cosmetics Regulation). Consequently, Butylphenyl Methylpropional will be banned from cosmetic products from 1st March 2022 and the ingredient will be included in the Annex II (list of substances prohibited in cosmetic products) of the European Cosmetics Regulation.
Cosmetic Products Regulation prohibits substances classified as CMR under the CLP Regulation from being used in cosmetic products, unless a specific exemption is granted.
Exemption conditions for CMR category 1A and 1B substances include:
Compliance with the food safety requirements as defined in Regulation (EC) No 178/2002;
There are no suitable alternative substances available;
The application is made for a particular use of the product category with a known exposure;
The substance has been evaluated and found safe by the Scientific Committee on Consumer Safety (SCCS) for use in cosmetic products;
BMHCA does not meet the criteria for exemption. The SCCS have previously concluded that the use of BMHCA is not considered safe for use in cosmetics (SCCS/ 1591/17). Subsequently, the EU Commission will include BMHCA into Annex II (prohibited substances) of the Cosmetic Product Regulation from 1 March 2022.
Please, remember that all products containing BMHCA must be off the shelf by this date.
Cosmetic products containing this ingredient can be reformulated, which means that new product safety reports must be performed and labels may need to be corrected.
49th IFRA Standard Amendment.
We would like to remind you of the 49th IFRA Standards Amendment The document assumes changes within the improved methodology for quantitative risk assessment, leading to a re-establishment of product classes.
Additional standards have been introduced, including new restrictions and the withdrawal of certain fragrances. Restrictions on the use of phototoxic substances in rinse-out products have also been taken into account.
The 49th amendment is effective from 10 February 2021 for newly introduced products and from 10 February 2022 for products that are currently on the market. The document directly concerns suppliers of raw materials, however, cosmetic manufacturers should contact their suppliers and verify that the new guidelines will not affect the need for changes in the formulation of products.
Changes should be of particular interest to manufacturers, who in the formulation of their cosmetics contain citrus essential oils. For more information, please read the IFRA documents