How to Create CLP Labels Step by Step

What You Need Before You Start

Before you design a single element, gather these five things. Missing any one of them will stall the process.

• Safety Data Sheet (SDS) from your fragrance / ingredient supplier — EU-format, REACH Annex II compliant
• Your product's complete formulation — every ingredient and its percentage by weight
• EU supplier or importer details — full legal name, street address, and telephone number
• A generated UFI code (see Step 6 or our dedicated UFI guide)
• Knowledge of which EU member states you will sell into — this determines label languages

If you are missing your SDS or formulation data, stop here and request them from your suppliers. Everything else in this guide depends on those two documents.

Step 1: Get Your Safety Data Sheet

The Safety Data Sheet is the foundation of your CLP label. It tells you which hazardous substances are present in your fragrance or raw ingredients, at what concentrations, and how they are classified under CLP. Without a proper SDS, you are guessing — and guessing is not compliant.

Where to Find the Key Information

An SDS has 16 sections. For CLP labeling purposes, two sections matter most:

• Section 2 — Hazards identification. This gives you the overall hazard classification of the fragrance or raw material, including hazard category, signal word, H-statements, and P-statements as supplied.
• Section 3 — Composition / information on ingredients. This lists each individual hazardous substance, its CAS number, its concentration range, and its CLP classification. This is the data you will use to classify your finished mixture.

EU-Format vs. US-Format SDS

If your supplier is US-based, they may have provided an OSHA HazCom 2012 SDS. While the GHS framework is similar, a US SDS is not the same as an EU SDS. The EU requires SDS to follow the format specified in REACH Annex II (Commission Regulation (EU) 2020/878). Key differences include the inclusion of REACH registration numbers, specific EU regulatory references, and Specific Concentration Limits from CLP Annex VI, Table 3.1.

If your supplier has not provided an EU-format SDS, request one explicitly. Any reputable fragrance house that sells to EU customers will have them available.

What to Check on Your SDS

• Section 3 lists individual substances with CAS numbers and concentration ranges
• CLP classifications use the current format (e.g., Skin Sens. 1B, H317)
• The SDS references Regulation (EC) No 1272/2008, not just OSHA HazCom
• It was issued or revised within the last 3 years
• Specific Concentration Limits (SCLs) are listed where applicable

Step 2: Classify Your Mixture

Your SDS tells you how the raw fragrance is classified. But you are not selling raw fragrance — you are selling a candle with 8% fragrance load, or a wax melt with 10%. You need to calculate the classification of your finished product based on the actual concentrations in the final mixture.

Calculate Ingredient Concentrations in the Final Product

For each classified substance in Section 3 of your SDS, multiply its concentration in the fragrance by the fragrance load in your product. For example:

• Linalool at 15% in fragrance x 8% fragrance load = 1.2% linalool in the finished candle
• Limonene at 5% in fragrance x 8% fragrance load = 0.4% limonene in the finished candle
• Citral at 2% in fragrance x 8% fragrance load = 0.16% citral in the finished candle

Compare Against Concentration Limits

For each substance, compare its final concentration against the applicable concentration limit. There are two types of limits under CLP Regulation (EC) No 1272/2008:

• Specific Concentration Limits (SCLs) — substance-specific thresholds listed in CLP Annex VI, Table 3.1. These override generic limits when they exist.
• Generic Concentration Limits (GCLs) — default thresholds that apply when no SCL exists for a substance. These are defined in CLP Annex I, Parts 3-5.

Key Generic Concentration Limits

Apply the Classification Calculation

For skin sensitization, CLP Annex I Section 3.4.3.1.2 uses an additive formula: sum each ingredient's concentration divided by its individual GCL (or SCL if one exists). If the sum of [Ci / GCLi] >= 1, the mixture is classified. This matters when you have ingredients with different sub-categories — a Cat 1A substance (GCL 0.1%) and a Cat 1B substance (GCL 1.0%) contribute differently. Simple example with identical categories: three skin sensitizers (Cat 1B) at 0.4%, 0.5%, and 0.3% = sum of 1.2% ÷ 1.0% GCL = 1.2 >= 1, so classified as Skin Sens. 1B.

For aquatic toxicity, CLP Annex I Section 4.1.3.5.5 uses a different summation approach with M-factors: Sum of [Ci × Mi] >= 25% triggers Aquatic Chronic 2. M-factors multiply a substance's contribution — a substance with M=10 at 3% concentration contributes 30% to the sum. Always check your SDS for M-factor values; omitting them can cause under-classification.

The result of this step is a list of hazard categories that apply to your finished product. A typical scented candle might end up classified as: Skin Sens. 1B, Aquatic Chronic 3. A heavily fragranced wax melt might pick up additional classifications like Eye Irrit. 2 or Aquatic Chronic 2.

Step 3: Select Your Pictograms

Each hazard category maps to a specific GHS pictogram. Based on the classification you determined in Step 2, select the pictograms your label needs.

Pictogram Precedence Rules

CLP includes precedence rules to avoid redundant pictograms on the label. Under CLP Article 26:

• If GHS05 (corrosion) appears, you do not also need GHS07 for skin or eye irritation.
• If GHS08 (health hazard) appears for respiratory sensitization, you do not also need GHS07 for respiratory sensitization.
• However, GHS07 for skin sensitization and GHS08 for aspiration toxicity target different hazard groupings — both appear on the label.

Minimum Pictogram Sizes

CLP Annex I, Section 1.2.1.3 specifies minimum pictogram dimensions based on package capacity:

For most candles and wax melts (packages well under 3L), the 16 x 16 mm minimum applies. If your packaging qualifies for the small-packaging derogation (CLP Article 29 — packages <= 125 mL), you may use 10 x 10 mm pictograms, but all other label elements must still be present.

Step 4: Write Your Hazard Statements

Each hazard category has a corresponding H-code with legally defined text. You must use the exact wording specified in CLP Annex III — you cannot paraphrase, shorten, or rewrite hazard statements.

Common H-Statements for Candles and Wax Melts

Each H-statement text is defined word-for-word in CLP Annex III, Table 1.1. The text must appear on the label in the official language(s) of the target market. You print the H-code itself on the label alongside the text (e.g., "H317 — May cause an allergic skin reaction").

Supplemental Hazard Information

Some classifications trigger EUH-statements — supplemental phrases unique to the EU that do not exist in the UN GHS system. For example, EUH208 ("Contains [name of sensitizing substance]. May produce an allergic reaction.") is required when a mixture is not classified as a skin sensitizer overall but contains an individual sensitizing substance above 0.1%. Check your formulation carefully against CLP Annex II, Part 2 for any applicable EUH-statements.

Step 5: Select Precautionary Statements

Precautionary statements (P-codes) tell the user how to safely handle, store, and dispose of the product. They are mapped from your H-codes using the tables in CLP Annex IV, Part 2.

Using Discretion Under CLP Article 28

Unlike H-statements, which are mandatory and non-negotiable, CLP Article 28 gives you limited discretion with P-statements. You may omit P-statements that are "clearly unnecessary" given the nature of your product. The classic example: P272 ("Contaminated work clothing should not be allowed out of the workplace") is triggered by skin sensitization, but it is plainly inappropriate for a consumer candle. You can — and should — omit it.

The overall goal is to keep P-statements practical and meaningful for the end consumer. A label overloaded with irrelevant precautionary advice is harder to read and less effective at communicating genuine safety information. CLP caps the number of P-statements at six unless more are needed to reflect the severity of the hazard.

Commonly Used P-Statements for Candles

For a solid wax candle sold to consumers, a practical selection might be: P102, P261, P280 (simplified to "Wear protective gloves"), P302 + P352, P333 + P313, and P501. That gives six P-statements — a reasonable, readable set.

Step 6: Generate Your UFI Code

The Unique Formula Identifier (UFI) is a 16-character alphanumeric code that links your product to the exact composition data you submit to EU Poison Centres. It has been mandatory on CLP labels for consumer products since 1 January 2025 under CLP Annex VIII.

How to Generate a UFI

• Go to the ECHA UFI Generator at ufi.echa.europa.eu.
• Enter your company's VAT number (or a company key if you don't have an EU VAT number).
• Enter a formulation number — a unique number you assign to each distinct formulation.
• The generator produces a 16-character UFI code in the format XXXX-XXXX-XXXX-XXXX.
• One UFI per unique formulation. If you change the formulation (even the fragrance percentage), you need a new UFI.

Poison Centre Notification (PCN)

Generating the UFI is only half the job. You must also submit a Poison Centre Notification through the ECHA Submission Portal, providing the full composition of your product (every ingredient, every concentration). This data is available only to Poison Centres for emergency medical treatment — it is not published or shared with competitors.

The UFI must be printed on the label preceded by the letters "UFI" in capitals: UFI: XXXX-XXXX-XXXX-XXXX. For detailed guidance, see our UFI code guide.

Step 7: Design the Label Layout

With all the CLP data elements gathered, it is time to assemble the physical label. The CLP Regulation specifies not just what must appear, but how it must be presented.

Required Visual Formatting

• Pictograms must be red-bordered diamonds (rotated squares) on a white background. They must not be printed in grayscale, blue, or any other color.
• Signal word ("Warning" or "Danger") must be prominent and clearly distinguished from surrounding text.
• All text must be clearly legible — CLP Annex I, Section 1.2.1.4 recommends a minimum font size of approximately 1.2 mm (x-height) for the smallest packages.
• The CLP label elements must be grouped together on the packaging. They should not be scattered across different faces of the container.

Practical Layout Tips

The most effective approach is to create a dedicated CLP block on your label, visually separated from your branding and marketing content. A typical layout arranges the elements in this order, top to bottom:

• Row 1: Pictogram(s) — displayed in a horizontal row
• Row 2: Signal word — "Warning" for most candle/wax melt classifications
• Row 3: Hazard statements — each H-code with its full text
• Row 4: Precautionary statements — selected P-codes with full text
• Row 5: Supplemental information — EUH-statements, allergen declarations if applicable
• Row 6: UFI code — "UFI: XXXX-XXXX-XXXX-XXXX"
• Row 7: Supplier identification — legal name, address, telephone number

Minimum Label Dimensions

CLP Annex I, Section 1.2.1.3 sets minimum label dimensions based on package capacity:

For many candle and wax melt packages, the label area is tight. If your package is too small to fit all CLP elements legibly, the small-packaging derogation under CLP Article 29 allows certain fold-out labels, attached tags, or outer packaging solutions. However, even under this derogation, pictograms, signal word, H-statements, and the UFI must still appear on the inner packaging.

Step 8: Translate for Your Target Markets

CLP Article 17(2) requires that CLP label elements appear in the official language(s) of the EU member state(s) where the product is placed on the market. English alone is not sufficient unless you are only selling in Ireland or Malta.

Language Strategy Options

Most Commonly Needed Languages

If you are targeting the major EU markets, plan for translations into:

• German — Germany, Austria, parts of Belgium, Luxembourg
• French — France, Belgium, Luxembourg
• Italian — Italy
• Spanish — Spain
• Dutch — Netherlands, Belgium
• Polish — Poland (large and growing e-commerce market)

Translation Quality Requirements

CLP label translations are safety-critical. Google Translate, DeepL, or any machine translation tool is not acceptable as a final source for H- and P-statement translations. The official translations of all H- and P-statements are published in each language version of the CLP Regulation itself. Use the official EU legal texts or a professional regulatory translator who works from them. Incorrect translations of hazard information can create real safety risks and regulatory liability.

Step 9: Print and Apply

The final step is producing the physical label and applying it to your packaging. CLP has specific requirements for label durability and placement.

Durability Requirements

• The label must be firmly affixed to the surface of the package (CLP Article 31(1)).
• Label text and pictograms must remain legible throughout the product's expected shelf life. Test for resistance to fading, smearing, and peeling.
• Pictograms must have a white background with a red border. Printing in grayscale is not compliant, even on black-and-white packaging.

Placement Rules

• The CLP label must not be obscured by other labels, stickers, or packaging seals.
• If the product has outer packaging (e.g., a gift box) and inner packaging (the candle jar), CLP labeling is required on the inner packaging at minimum. If the outer packaging itself is a "package" under CLP, it also needs labeling.
• For online sales, CLP label information must also be displayed on the product listing page at the point of sale.

Pre-Shipment Quality Check

Before shipping a production run, pull a sample label and verify:

• All pictograms are printed in color (red diamond border on white)
• Signal word is present and legible
• All H-statements include both the code and the full text
• P-statements are present and appropriate for the product type
• UFI code is printed and preceded by "UFI:" in capitals
• Supplier name, address, and telephone number are included
• All required language translations are present and correct
• Label is firmly affixed and does not peel or smear

Label Design Checklist

Use this checklist to verify that every required element is present on your CLP label before going to print. Every item below is mandatory under CLP Article 17 unless otherwise noted.

• Product identifier — trade name PLUS names of substances contributing to the classification (up to 4) per CLP Article 18(3)(b). For skin sensitization, the sensitizing allergens must be named here.
• Supplier identification — company name, full address, and telephone number
• Nominal quantity — net weight or volume (required if product is also supplied to the general public)
• GHS pictogram(s) — red-bordered diamond on white, correctly sized for package capacity
• Signal word — "Danger" or "Warning" (never both; use the more severe if multiple apply)
• Hazard statements — every applicable H-code with its verbatim text from CLP Annex III
• Supplemental hazard information — EUH-statements where applicable (e.g., EUH208 for sub-threshold sensitizers)
• Precautionary statements — selected P-codes with full text, no more than six unless hazard severity requires it
• UFI code — 16-character code preceded by "UFI:" in capitals
• Allergen declaration — names of sensitizing substances present above 0.1% (triggered by EUH208 or classification)
• All text in the official language(s) of each target market
• Label dimensions meet the minimums in CLP Annex I, Section 1.2.1.3
• Pictogram dimensions meet the minimums (16 x 16 mm for packages up to 3L)
• All text is clearly legible (minimum ~1.2 mm x-height recommended)

Common Label Design Mistakes

These are the errors that most frequently cause labels to fail compliance reviews or trigger marketplace listing rejections. Every one of them is avoidable.

Pictogram Errors

• Pictograms printed too small. The diamonds must meet the minimum size for your package capacity. Shrinking them to "fit" is not compliant.
• Wrong color. Pictograms must have a red border on a white background. Black borders, grayscale printing, or colored backgrounds are all non-compliant under CLP Annex I, Section 1.2.1.
• Missing pictograms. Failing to include all pictograms required by the classification, or incorrectly applying the precedence rules.

Statement Errors

• H-statements paraphrased. "May irritate skin" is not the same as "May cause an allergic skin reaction" (H317). The text is legally defined and cannot be modified.
• P-statements inappropriate for product type. Including P272 (workplace clothing) on a consumer candle, or P273 (avoid release to environment) when you have no aquatic classification. Each P-statement must be justified by the hazard classification.
• Missing signal word. "Warning" or "Danger" must appear. It is not optional.

UFI and Supplier Errors

• Missing UFI code. Required on all consumer hazardous mixture labels since 1 January 2025. No UFI = non-compliant.
• UFI not preceded by "UFI:" in capitals. The format is "UFI: XXXX-XXXX-XXXX-XXXX" — the prefix is mandatory.
• No Poison Centre Notification submitted. Generating the UFI without submitting the PCN means Poison Centres cannot look up your product in an emergency.
• Supplier details missing or incomplete. The label must show the name, address, and telephone number of the supplier responsible for placing the product on the EU market.

Language and Market Errors

• English only. Unless you are exclusively selling in Ireland or Malta, an English-only label does not satisfy CLP Article 17(2). Germany, France, Italy, Spain, and most other member states require their official language(s).
• Machine-translated H/P-statements. The official translations are published in the CLP Regulation itself. Using Google Translate for safety-critical text creates both legal risk and genuine danger.

If you catch these mistakes before your first production run, you will save significant time and money on reprints and re-labeling. When in doubt, cross-reference every label element against CLP Regulation (EC) No 1272/2008, Article 17 and the annexes cited throughout this guide.