Fresholi | Melting Pot Café

In case it has escaped you there are new regulations for candle labelling from June. How we fit everything on a votive label is beyond me!

http://www3.hants.gov.uk/.../tsguide-candlesafety... (http://www3.hants.gov.uk/.../tsguide-candlesafety...)

The page has moved.

http://www3.hants.gov.uk/tradingstandards/tradingstandards-business/ts-business-safety/tsguide-candlesafety-business.htmI?hc_location=ufi (http://www3.hants.gov.uk/tradingstandards/tradingstandards-business/ts-business-safety/tsguide-candlesafety-business.htmI?hc_location=ufi)

based on that information, (which I would like to thank you first for posting, very important stuff!), then what we are already doing is OK? I have a text warning label on all my candles, and it says the information in table 1 is mandatory in EITHER pictogram OR text format, if in text, then must be in the language of the country being sold. Table 2 info is advised, but not mandatory. Now, Have I understood that correctly?  :mwaha:

I don't know what you are asking me for, I am confused.  :mwaha:

That is what that looks like it is saying. However, if you look here...
http://www.hse.gov.uk/chemical-classification/legal/clp-regulation.htm?hc_location=ufi
 (http://www.hse.gov.uk/chemical-classification/legal/clp-regulation.htm?hc_location=ufi)then we need to label differently.

but there is no mention of anything other than chemicals in that link  ??? ??? ??? so how does that relate to candles? (not asking you Suzanne! just anyone out there who may have a clue!) :mwaha:

substances....mixtures.....could they be any more vague, why not just say stuff and things??? :mwaha:

See, see it's not just me.

Somewhere it does say candles are included. They are articles apparently.

http://www.complianceservices.com/wp-content/uploads/2014/10/EU%E2%80%99s-Classification-Labeling-and-Packaging-Regulations-CLP.pptx?hc_location=ufi
 (http://www.complianceservices.com/wp-content/uploads/2014/10/EU%E2%80%99s-Classification-Labeling-and-Packaging-Regulations-CLP.pptx?hc_location=ufi)

Slide 28 says
"If a candle contains any sensitizing fragrance ingredient at more than 0.1%, the label should bear the statement “Contains (name of fragrance(s)).  May produce an allergic reaction.”
If a candle contains more than a total of 1% sensitizing fragrance ingredients, it should bear the exclamation point pictogram, the signal word WARNING, and have the statement  “May cause an allergic skin reaction” and list some ingredients.
The greater the concentration of fragrance in the candle, the more likely that it will trigger one or more of these warnings."

So....what are the "some ingredients" we are to list?

I just got this from candleshack ...

It made me think its now as complex to label candles as soap ........  :tantrum:


CLP Demystified
What is CLP and what does it mean for your business?
Classification, Labelling and Packaging (CLP) is the European Unions implementation of a larger United Nations (UN) agreement called the Globally Harmonised System (GHS) relating to the classification and labelling of chemicals.

Amongst other things, it aims to standardise the way in which products containing chemicals are labelled worldwide.  Whilst GHS is voluntary, CLP is law and applies to businesses of all sizes within the EU.  It comes into force on the 1st June 2015 and applies to many different products, including fragranced products such as candles, diffusers, melts and more.

For home fragrance products, such as candles, CLP will require pictograms and a number of risk phrases to be included on containers and packaging.  Here are some CLP pictograms that are likely to be applicable to many home fragrance products..


The actual pictograms and risk phrases required will depend on the exact mixture (i.e. wax and oil).  So, a mixture would be defined as a particular blend of base and oil; i.e. candle wax with 8% 'Pure Eden' fragrance.  A candle using a different oil or even a different concentration of the same 'Pure Eden' (i.e. 12%) will likely have different phrases and pictograms and would therefore require different labels. 

CLP labels and Safety Data Sheets (SDS) are produced using fairly expensive software (£5k-£20k + annual fees) that references the 1400+ aroma chemicals in the IFRA chemical database.  The software works out how much of each ingredient is in the 'mixture' and using the reference data, produces a series of phrases and pictograms applicable to that specific blend (mixture) as well as an SDS.

The good news....
At Candle Shack, we have purchased the software and completed training, so intend to help our customers by making CLP label and SDS data available for all of the fragrances we stock.  We will provide the pictograms and risk phrases for each fragrance, for both candles and diffusers based on 10% perfume load in candles and 15% load (in Augeo) in diffusers.  These will be available on the perfume pages before 1 Jun 15, which is the deadline for the classification and labelling of 'mixtures'. 

We will also be posting a video before the 1st of June explaining in more detail the requirements for labelling candles for both CLP and fire safety, as we have seen many non-approved pictograms being used on forums etc.  We hope this will help smaller companies stay on the right side of the law and provide much needed advice in an easy to understand format.

More Information...
CLP is a huge and very complicated subject and whilst we will ensure that our products are supplied with the correct information and will do all that we can to help our customers in terms of labelling, we regret that we will not normally provide CLP labels of SDS for fragrances purchased from other suppliers. We are also not CLP advisers, so would ask that you take the time to research CLP before contacting us, particularly for general CLP information.  Detailed information on GHS and CLP can be found here...

HSE Website

 

The issue I have at the moment (apart from the fact the pictograms are so stupid, no one will understand them) is knowing when I have to label what. I use mainly EO's so which are classed as sensitising fragrances and which are not? I assume that we are going to label the allergens.

I'm the same Suzanne, just using EOs and I'm assuming (but could be wrong because I don't really understand these things  ;)) that we take the same approach as we would for cosmetics, as in listing the EOs used, then listing the allergens. Or at least thats what I intend to do until I'm told different.

and there was me thinking candles might be a good idea......

 :mwaha:

OK, so, all my candles are in boxes. the only way for me to include all of this information is to put a leaflet type thing inside each box. I simply do not have room to put another sticker on the candle (I currently put the warning label on the bottom - my jars are shaped and decorative, warning lables would not fit or stick, and they would look terrible too) Unless frangrance suppliers can supply those fold out type labels with multi layers??

I read somewhere that the label has to be fixed to the candle container not just on the box or in the box and that it has to be visable when the candle is set down, so it can't be hidden on the bottom either. It will undoubtedly make them look unslightly! The best solution I can think of is to place it to the back of the container but its not ideal :-\

As I understand it, you can provide a leaflet. It can be at point of sale and does not have to be on the candle. Now I'm on a box hunt!

Good. will do that then. thankyou! :buttrf:

OK, just a thought....how do we deal with US FO's MSDS and allergen decs, as we've never needed them before, and quite a few of my canlde fragrnaces are US oils. WIth the UK oils, obviously we have the MSDS and allergen data, so no problems with those.

Sorry but I don't think that is the case, the label needs to be firmly attached to the packaging according to 3.1 of the CLP document
http://echa.europa.eu/documents/10162/13562/clp_labelling_en.pdf

Guidance on labelling and packaging in accordance with the CLP Regulation

3. PRINCIPAL REQUIREMENTS OF LABELLING AND
PACKAGING IN ACCORDANCE WI
TH THE CLP REGULATION
3.1 General labelling rules
General and specific rules regarding the content and application of a CLP label are set out in
CLP Title III, Chapters 1 and 2, respectively. 
As a general rule, CLP requires labels to be firmly affixed to one or more surfaces of the
packaging immediately containing the substance or mixture and that they shall be readable
horizontally when the package is set down normally, see CLP Article 31(1). The label elements
themselves, in particular the hazard pictograms,
 shall stand out clearly from the background,
see CLP Article 31(2) and (3). Furthermore, all label elements shall be of such size and spacing
as to be easily read. A physical label is not
required when the label elements are shown clearly
on the packaging itself, see CLP Article 31(5).

I think it would be ok on the outer box though perhaps, maybe... who knows  ???

This is what TS said "This standard specifies the format and content of product warning labels for indoor candles. The standard requires that all information supplied with a candle is presented in a clear format on the product and should be easily and non-verbally comprehensive. Such warnings may be on the product or packaging itself or available as a separate leaflet if appropriate."

All as clear as mud then!

The regs do say

"Small packaging exemptions

CLP provides certain exemptions for substances and mixtures contained in packaging that is small (typically less than 125ml) or is otherwise difficult to label. The exemptions allow the supplier to omit the hazard and/or precautionary statements or the pictograms from the label elements normally required under CLP."

My largest candle is 30cl. Please tell me that means I don't have to put the exploding fish on my small candles.

It looks that way doesn't it?  I am not familiar with any of this and can't offer anything but I do now have this image of an exploding fish stuck in my mind.  That'll make for pleasant dreams tonight  :mwaha:

It is worse than the cosmetics regulations. At least then we had Scoot to point us in the right direction. With this, everyone is running in circles not understanding anything.

(And at least I didn't say the exploding fish was on me smalls) :mwaha:

 :egad:

I think if we treat them the same way as we would a cosmetic product, i.e. same type of labelling etc, we can't go far wrong. Then just keep an eye on what others are doing and follow suit. There is a 2 year grace period, so it gives us of plenty of time to get our heads round it because I can't imagine them taking action on anyone during that 2 year transition :)

I think there is a 2 year grace period for product made and in stock before the regulations come in to place rather than made after, but in the 2 year period, but I could be wrong.

sorry haven't had time to read the regs yet busy patch at work and have a friend staying, but following the discussion and hopeful can contribute later

Devious of me to think this, but how would they know when the candles were made? It's not mandatory to keep batch logs for candles :) Easy to say that the candles were made before the regs.

That thought has already crossed my mind.

mine too  :mwaha:

also mine

Pretty much what my TS said this afternoon!