CLP Regulations: Product Labelling

What is CLP and why does it matter?

CLP stands for Classification, Labelling and Packaging. It is retained EU law (now UK CLP Regulation) that ensures consumers are warned about hazardous chemicals in products they buy. Fragrance oils and essential oils contain chemical compounds that are classified as hazardous; they can be irritating to skin, harmful to aquatic life, or cause allergic reactions.

As the person placing the product on the market, you are legally responsible for making sure labels are correct. 'I didn't know' is not a defence.

What needs to go on the label?

A CLP-compliant label must include:

• Product identifier: the product name and the chemical identifiers of the hazardous substances (usually the fragrance compounds).
• Hazard pictograms: the red-bordered diamond symbols (e.g. the exclamation mark for irritants, the dead fish/tree for environmental hazards).
• Signal word: either 'Warning' or 'Danger' depending on the severity.
• Hazard statements (H-phrases): standardised phrases describing the hazard, e.g. 'H317: May cause an allergic skin reaction'.
• Precautionary statements (P-phrases): standardised advice on handling, storage, and what to do if something goes wrong.
• Supplier information: your business name and contact details (a website or email is acceptable).
• Quantity: the nominal quantity of the product.

The label must be in English, legible, and indelibly marked. It must be on the product itself, not just on a leaflet tucked inside the packaging.

Where do I get the information?

Your fragrance oil or essential oil supplier must provide you with a Safety Data Sheet (SDS) for each oil. The SDS contains all the hazard classifications, H-phrases, and P-phrases you need. If your supplier cannot provide an SDS, find a different supplier.

You then need to work out the classification of your finished product based on the concentration of hazardous substances in your recipe. Many suppliers provide CLP label templates or calculators to help with this.

Top tip: keep your SDS files organised by product, as you may be asked to produce them at a craft fair or by Trading Standards.

Common mistakes

• No label at all: 'it's just a candle' is not an exemption.
• Using generic labels that do not match the specific fragrance; each scent may have different hazard classifications.
• Missing pictograms or using the wrong ones.
• Printing labels too small to read; there are minimum size requirements based on package volume.
• Forgetting supplier details: your label must say who made or supplied the product.
• Relying on a sticker on the bottom of a tin that falls off; labels must be durable.

Enforcement

Trading Standards officers visit craft fairs and can ask to see your labels and SDS documentation. If your products are not labelled correctly, they can:

• Issue informal advice and give you time to fix it.
• Issue a formal notice requiring compliance.
• Seize non-compliant products.
• In serious or repeat cases, prosecute.

Most officers want to help you get it right, but you need to show willing. Having your SDS files to hand and showing you understand the requirements goes a long way.

What would Trading Standards ask to see?

Trading Standards officers have the power to enter any premises where business is being conducted, including a craft fair stall, to inspect products and require the production of documents (Consumer Rights Act 2015, Schedule 5; Business Companion: Trading Standards powers). For products under CLP, they do not need to give notice if the visit is for market surveillance purposes under product safety legislation.

If a Trading Standards officer visits your stall, they can ask to see:

• **Your product labels**, checked against the CLP classification for each fragrance. Each scent has its own hazard profile; a generic label used across different fragrances is a common reason for enforcement action.
• **Safety Data Sheets (SDS) for every fragrance oil or essential oil you use.** The SDS is the source document for your CLP classification. The guide already says "keep your SDS files organised by product, as you may be asked to produce them at a craft fair." This is not a suggestion; it is the practical reality of a Trading Standards visit.
• **Your CLP classification assessment for each product.** This is the working document showing how you calculated the hazard classification of your finished product from the SDS data for each ingredient. It links the SDS to the label.
• **Your UFI (Unique Formula Identifier) registration**, if applicable. The UFI links your product to its formulation in the event of a poisoning incident.
• **Your supplier details.** Officers can require you to identify who supplied the fragrance oils or essential oils you use.

If you cannot produce your SDS files and classification assessments, an officer is within their rights to issue advice, serve a formal compliance notice, or in serious cases seize non-compliant products from your stall (Business Companion: Trading Standards powers).

The good news: if your documentation is in order, most officers will tell you so and move on. Having your SDS files organised by product and your classification assessments accessible on your phone or in a folder at your stall is the single best thing you can do to prepare. **Your StallSync Event Passport is designed to hold exactly these documents: SDS files, classification records, and your signed CLP attestation, all in one place on your phone.**