Instruction for CLP, UFI Code and ECHA

Overview and Preparation for Your Candles  

This topic applies to all fragrances that require a UFI code, regardless of the manufacturer.  
Objective: Create a correct CLP label with your own UFI code, enter all data into the ECHA database, and submit the PCN notification.  
Requirements: You must already be producing candles with fragrance oils and have access to relevant safety data (such as the ingredients of the fragrance oil).  
Important: If you use our fragrances as a private individual, you do not need to follow these steps. However, if you sell candles but purchase fragrance oils from us without a UFI code, you do not need an ECHA and PCN notification. A CLP label is still mandatory.  


Fragrance Oil and Candle Making: What You Need to Know  

Safety Data of the Fragrance Oil: Ensure that safety data sheets are available for all fragrance oils used in your candles. These contain information on hazardous substances, labeling, and handling.  
Fragrance Oils Without UFI Code: Special safety and labeling requirements apply to fragrance oils without a UFI code. Check whether additional regulations apply, particularly regarding allergens and toxic substances. You can find UFI-free fragrances in our catalog.  
 

How to Determine in 3 Simple Steps (If You Need a PCN Notification for Your Candle)


1. Step 1:
Open the 5% or 10% safety data sheet and look for section 2.2 "Label Elements."  

1/3. Signal Word:
   - None = Not required  
   - Warning = Partially required ***  
   - Danger = Required  

2/3. GHS Hazard Symbols:
   - None = Not required  
   - Only GHS09 (Fish/Environment) = Not required  
   - Only GHS07 (Exclamation Mark) = Partially required ***  
   - Any combination of GHS symbols, such as Fish and Exclamation Mark, Corrosive, Toxic = Required  

3/3. Hazard Statements (Hxxx codes):
   - No Hxxx codes = Not required  
   - Only H4xxx codes = Not required  
   - Above approx. H318 = Partially required  
   - H3xx codes = required ***

   ***This is approximately the threshold for UFI obligation.  
 

Key Terms  


CLP Label (Classification, Labeling, and Packaging): An EU regulation that classifies, labels, and packages chemical products to ensure safety.  
UFI Code (Unique Formula Identifier): A 16-character alphanumeric code used to uniquely identify chemical mixtures in the EU. You are required to generate your own UFI codes.  
ECHA (European Chemicals Agency): An agency where chemicals must be registered to ensure compliance with the REACH regulation.  
PCN (Poison Center Notification): A notification for products containing hazardous chemicals that are sold in certain European countries. It must be submitted to ECHA.  
 

Step-by-Step Guide  


1. Creating a CLP Label
  • Hazard Classification:Use the fragrance oil's safety data sheet to determine the classification (see section 2.2). Check if the fragrance is considered hazardous (e.g., harmful to health or the environment).  
  • Symbols and Pictograms: Depending on the classification, the label must include specific hazard symbols and warnings (e.g., "Harmful to Health," "Harmful to the Environment").  
  • Safety Instructions: Include warnings like "Danger" or "Warning."  
  • Additional Information: Ensure that all fragrance oil ingredients are correctly listed on the label, especially those classified as allergens.  
  • UFI Code: If required, generate a UFI code using the appropriate generator.  
  • Batch Number: Used for product identification. Combine an item number and date, e.g., 13000240325 (13000 + 24.03.25).  
  • Your Information: Name, address, and contact details must be included.  

2. Generating a UFI Code

You are required to generate a unique UFI code for your candles.  


3. Entering Data into the ECHA Database

ECHA Portal: Register your product if it contains relevant chemical substances. The registration includes ingredient details, packaging, and labeling information.  
REACH Compliance: Ensure that the fragrance oils used comply with the REACH regulation. If not, registration may be required.  


4. Submitting the PCN Notification

Why is a PCN Notification Required?
If your fragrance oil contains hazardous chemicals that pose a health risk, a PCN notification must be submitted.  
Submitting the PCN Notification: Register your product via the national poison center portal if you use a fragrance oil classified as hazardous.  


5. Documentation and Archiving

Safety Data Sheets: Ensure all safety data sheets for fragrance oils and other raw materials are properly stored and available upon request.  
Proof of ECHA and PCN Submissions: Keep all confirmations and documents proving that you have made the necessary registrations.  


6. Updates and Regular Checks

Review: Regularly check safety data sheets and legal requirements, as regulations may change. Fragrances may also be reclassified over time.  


>> More about ECHA
>> More about UFI codes


 

Back