Not Every Candle Requires Registration – But Every Candle Requires Compliance: REACH, CLP and GPSR Regulations in the EU and UK

How Annel supports candle manufacturers in achieving full regulatory compliance and product safety

The European scented candle market continues to expand — and with that growth comes increased responsibility for manufacturers and importers to ensure product safety and regulatory compliance.

While not every candle requires registration under REACH or CLP, every single one must meet the requirements of the General Product Safety Regulation (GPSR) and include proper labelling and traceability information.

Candles (including wax melts) are considered chemical mixtures, and their composition and labelling must comply with REACH and CLP (or their British equivalents, UK REACH and UK CLP). Even if a candle contains no hazardous substances, it is still subject to EU GPSR / UK GPSR, which requires it to be safe, properly labelled, and traceable.

🇪🇺 European Union: REACH, CLP and EU GPSR

1. REACH and CLP – The Chemical Compliance Framework

Candles sold within the EU are treated as chemical mixtures. If they contain hazardous substances (e.g. fragrance allergens), they fall under:

REACH (EC 1907/2006) – Registration, Evaluation, Authorisation and Restriction of Chemicals
CLP (EC 1272/2008) – Classification, Labelling and Packaging Regulation

🔹 Key Obligations for Manufacturers or Importers:

Classification of the mixture:
- Assess potential hazards based on fragrance oils, waxes and dyes.
- The most common risk for candles is skin sensitisation (Skin Sens. 1, H317).
Labelling:
- If a candle contains a sensitising substance:
PCN and UFI:
- For hazardous mixtures, manufacturers must submit a Poison Centre Notification (PCN).
- Label the product with a Unique Formula Identifier (UFI).
Packaging:
- The CLP label must appear on the product’s packaging, not directly on the wax.
- Open jars or tealight foils are not considered compliant packaging formats.

🧩 Candle makers are typically considered downstream users, meaning they are not always required to register substances under REACH — but they are still responsible for correct classification and labelling.

2. EU GPSR – Product Safety Beyond Chemistry

Since 13 December 2024, the EU General Product Safety Regulation (EU 2023/988) has applied to all consumer products, including candles.

Every candle placed on the EU market must:

Have a designated Responsible Person (RP) established within the EU
Maintain technical documentation and a product safety assessment
Comply with harmonised standards EN 15426, EN 15493 and EN 15494
Include the manufacturer’s details and a batch or product reference number

Learn more about the Responsible Person role:
👉 Responsible Person – Your Strategic Partner in Global Expansion

Authorised Representative (EAR) vs. Responsible Person (RP)

Under the EU General Product Safety Regulation (EU 2023/988), every product sold in the EU, including candles, must have a Responsible Person (RP) established within the Union if the manufacturer is located outside the EU.

Role of the Responsible Person (RP):

Acts as one of the EU’s economic operators, ensuring legal compliance and product safety
The RP can be a manufacturer based in the EU, an importer, an Authorised Representative (EAR), or a fulfilment service provider
The RP serves as the official market surveillance contact, ensuring technical documentation is available and coordinating any corrective actions if required

In summary:

For candle producers outside the EU, an Authorised Representative (EAR) can act as the Responsible Person (RP) under EU law.
Annel provides both EAR and RP services for manufacturers placing candles on the EU and UK markets.

🇬🇧 United Kingdom: UK REACH, UK CLP and UK GPSR

Following Brexit, the UK implemented its own regulatory framework:

UK REACH
UK CLP Regulation
The General Product Safety Regulations 2005 (UK GPSR)

UK REACH and UK CLP – Chemical Compliance

If a candle contains hazardous substances, registration is required through a UK-based importer. Classification and labelling requirements mirror those under EU CLP.

UK Responsible Person (UK RP)

In the UK, manufacturers based outside Great Britain are required to appoint a UK Responsible Person (UK RP) to act as their authorised point of contact for product safety and market compliance.

The UK RP ensures that products placed on the market meet all applicable safety and labelling standards in line with UK GPSR and UK CLP regulations.

Annel acts as a UK Responsible Person (UK RP), providing regulatory representation and compliance assurance for candle manufacturers entering the British market. Our role includes:

Verifying documentation
Maintaining product safety files
Serving as the official contact for UK market surveillance authorities

No Hazardous Substances ≠ No Obligations

Even if a candle does not contain hazardous ingredients, compliance obligations still apply. Every candle — regardless of composition — must:

Comply with EU GPSR and UK GPSR
Include safety and warning labels
Provide traceability (manufacturer and batch number)
Meet EN / BS EN 15494 safety standards for fire behaviour

Learn more here:
👉 Candle Regulatory & Compliance Services

💼 How Annel Supports Candle Manufacturers

At Annel, we guide candle brands and fragrance companies through every stage of regulatory compliance — from formulation review to labelling and technical documentation. We act as your Responsible Person (RP) in the EU and UK, offering complete regulatory representation.

Our Services Include:

Acting as Responsible Person
Mixture classification (REACH / CLP / UK REACH / UK CLP)
Preparing CLP and GPSR-compliant labels
Drafting SDS, UFI and PCN documentation
Advising on EN and BS EN safety standards
Liaising with market surveillance authorities

Discover more:
👉 Annel Services for Candle Manufacturers

With Annel, your candles don’t just smell beautiful – they’re safe, compliant and ready for every market.
Compliance made simple. Expansion made possible.

Summary

Not every candle requires REACH registration, but every candle must comply with CLP and GPSR in both the EU and UK.
Safety, transparency and accountability form the foundation of consumer trust.

🔗 Learn more about Annel’s Candle Compliance Services

📞 Contact us – we’ll help you safely bring your candles to market.

FAQ

Does every candle require REACH registration?
No. If it does not contain hazardous substances above classification thresholds, registration is not required – but GPSR obligations still apply.
Do natural candles also need warning labels?
Yes. All candles must include safety and manufacturer information, regardless of composition.
Are the EU and UK regulations the same?
Not exactly. They are closely aligned but independent. The UK uses UK REACH, UK CLP and UK GPSR.
Can Annel act as Responsible Person in both regions?
Yes – we maintain offices in both the EU and UK, offering full compliance and representation services.