2025 EU CLP Refresh: What UK Candle & Wax‑Melt Makers Need to Know
New hazard classes for endocrine disruptors and nanoforms land in the EU’s Classification, Labelling & Packaging (CLP) Regulation this year. If you sell into the EU—or into Northern Ireland—you’ll need fresh artwork, updated SDSs and airtight version control. Here’s your plain‑English guide.
1. Why the rules are changing
The EU’s Green Deal aims to “close the toxicity gap”. That means flagging chemicals that interfere with hormones (endocrine disruptors) or that contain nano‑sized particles (nanoforms). The updated CLP adds dedicated hazard classes so consumers see the risk front‑and‑centre—candles and melts are classed as mixtures, so they’re in scope.
2. The two new hazard areas
Endocrine Disruptors (ED)
- ED HH 1 / 2 – human health
- ED ENV 1 / 2 – environment
Watch for four new EUH statements: EUH380, EUH381 (human) and EUH430, EUH431 (environment).
Nanoforms
If any ingredient remains nano‑sized in the finished wax, add “(nano)” after the substance name on the SDS and, where space allows, on the label.
3. Deadlines & grace periods
- New substances: classify & label by 1 May 2025
- New mixtures (your candles/wax melts): classify & label by 1 May 2026
- Existing stock sell‑through: allowed until 1 Nov 2026 (substances) / 1 May 2028 (mixtures)
4. What stays the same in Great Britain
GB froze its CLP at the 2020 version. You still use the familiar pictograms, signal words and H‑/P‑statements. The Health & Safety Executive (HSE) is consulting on whether to mirror the EU’s new hazard classes, but no adoption date exists.
5. Action checklist for UK exporters
- Request updated SDSs for every fragrance, dye and additive.
- Self‑classify finished blends against the new ED and nano criteria.
- Create dual artwork: one EU‑compliant label and one GB‑only version.
- Add QR or peel‑back labels if space is tight.
- Version‑control and archive each label for 10 years.
- Train fulfilment teams to pick the right label roll for each destination.
- Mark your calendar for the phased sell‑through deadlines.
6. Quick FAQ
Do hobby sellers need to comply? Yes—if you place products on the EU or NI market, even via Etsy.
What if my jar is tiny? Use a peel‑back layer or QR linking to full hazard text. The short‑form label must still include pictograms and the signal word.
Is “nano” common in candles? Mica pigments, titanium dioxide and UV filters can all exist as nanoforms. Ask your pigment suppliers for particle‑size data.
7. CLP Refresh in Plain English
If the jargon above made your eyes glaze over, here’s the nutshell version:
- New warning lines – EU labels will soon say if an ingredient can mess with hormones (endocrine disruptor) or carries nano‑sized particles (nano).
- No new icon if safe – If your blend doesn’t meet these new hazard criteria, keep the label you already use; no extra pictograms or statements needed.
- Key dates – update EU labels by 1 May 2026; older stock can sell until 2028.
- GB unchanged… for now – mainland UK labels stay as‑is unless HSE adopts the same rules.
- Selling to EU or Northern Ireland? Keep two label versions—one classic GB, one shiny new EU file.
- Start tomorrow – email suppliers for new safety sheets and tweak your artwork early; no last‑minute panic!
