UNDERSTANDING CLP Regulations & IFRA CLASSIFICATION
EU’s Classification, Labelling and Packaging Regulations (known as CLP).
CLP (European Regulations (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures) came into force in 2009 (January) in all EU Member States, which also includes the UK. It was agreed by the EUL (European Union Level) that as from the 1st June 2015 these rules would apply including the UK. EN15494 provides some standardized fire safety warnings that most manufacturers choose to include, communicating perhaps the greatest risk posed by a candle. CLP only applies to Home Fragrancing Products (Not – Cosmetics) which are classed under separate rules. CLP effects the following Products: - Reed Diffusers, Wax Melts, Scented Sachets, Room Spray, Candle etc. (Including any other products that may fall into this category) Many fragrances ingredients, are known eye/skin irritants, skin sensitizers or are environmentally hazardous substances, if present at concentrations above the cut-off values listed in section 16 on the SDS, they trigger health or environmental warning statements and/or pictograms which should then be clearly stated on any labelling/packaging.
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. Please Note: - The information provided is based on our understanding of the New CLP Legislation so far. We have tried to simplify as much as we can for your understanding, we will continue to update, as we gain further in-depth information on any additional requirements.
CLP Labelling Technical Support
We are fully equipped with upto date CLP software that has enabled us to provide all necessary information regarding labelling requirements that conform to the new CLP regulations. All relevant information is available to download direct from the website, which will also include standard Product Labelling information for the following products: Candles based @ max 10% ratio and Reed Diffusers @ max 20% ratio formulation including the SDS for the finished product and the SDS, IFRA & Allergen Declarations for the fragrance oil. Please Note: The information will be provided in good faith and is to the best of our current knowledge but may be subject to change. Furthermore, it only represents the CLP contribution of the fragrance components and does not take into consideration any other ingredients that may be contained within the final product. The ultimate responsibility for the classification and labelling of the final product lies with the person placing it on the market. We recommend that this is determined using the information contained within the SDS of the neat fragrance in conjunction with that of the other ingredients within the final product.
Product Label (CLP) & Safety Precaution Information
Alternatively, you can download the product Label Information file for Candles @ 10% ratio and Reed Diffusers @ 20% unless otherwise stated See IFRA 49 Category 10A. On our website listed under each fragrance type in the technical information tab. Please also remember that all products including Candles, Diffusers, Rooms spray etc. also require standard safety precaution information for use: - Please see examples of the information you will need to add to your labels including. Direction of Use & Precautions for use/safety information for Candles & Reed Diffusers
Custom SDS (CLP) Documents
You can download any of the documents relating to the CLP regulations which can be edited so you may add your own details, Company Logo, fragrance name etc.. This can be done using a PDF editing software or Adobe Illustrator. If you are unable to edit the documents we are now offering a service to do this for you. The administration charge for this service is £15 ex vat. For further information about this service or to request Custom Documents Please Email Us for a quote Please Note:-We require the following information from you:
- Company Name, Address, Telephone No and Email address.
- Company Logo (if required) in the form of a jpg
- Our Fragrance Name & Code as reference and the name your company uses.
Once we receive this information we will send you a PayPal request for payment. All document will be emailed to you direct in 5 to 7 working days. Please contact us if you are unsure about the new legislation.
What is the difference between IFRA & CLP?
IFRA Standards and the CLP Regulation are separate. IFRA produce IFRA Standards which ban, restrict, or set criteria for the use of certain fragrance ingredients, to ensure the safe use of fragrance for consumers. Adhering to IFRA standards is mandatory for IFRA members only. The CLP Regulation ensure that fragranced products (excluding cosmetics) are classified, labelled, and packaged in a consistent way so that the hazards of the products are clearly conveyed to consumers. If your product is hazardous according to CLP, it is your legal responsibility to classify, label and package it appropriately.
What is IFRA?
The International Fragrance Association (IFRA) is the global representative body of the fragrance industry. It represents the collective interests of the industry and promotes the safe use of fragrances. The Association was founded in 1973. IFRA’s head office is based in Geneva, Switzerland and its operations centre in Brussels, Belgium. Its members are 8 multinational companies (known as 'Regular Members') and 21 national associations, covering 23 countries. There are 8 'Supporting Members' from countries where IFRA does not have a national association.
What are the IFRA standards?
The fragrance industry has developed a system to manage the safe use of fragrance: the IFRA Standards. The rules are developed in partnership with members and other stakeholders in a transparent process overseen by independent experts.
IFRA periodically issue “Amendments” to the IFRA standards, which is guided by the latest scientific evidence to assess the wide range of fragrance ingredients, referred to as “The perfumers Palette” IFRA sets the Maximum does of all natural & synthetic fragrance materials in the finished product. The amendments can result in the removal or restrictions in use of commonly used fragrance ingredients.
IFRA 49th Amendment
The 49th Amendment was the first major amendment since June 2015. Below we have highlighted the changes, impacting the home fragrance market.
Due to the reclassification under IFRA 49 reed diffusers, are now classed as a skin contact product and therefore this is causing some restrictions reducing the MAX % that can be used in the finished product. Reed Diffuser have been moved from Category 11 to Category 10A, which carries much stricter usage guideline than previously. Unfortunately, these changes have had an impact on certain fragrances that had been previously approved @ 20%, which can no longer be used at the level after the 10th May 2022.
How will you know if a particular fragrance oil has been affected?
We are advising that you check IFRA classification 10A for the latest MAX ratio allowing in your Reed Diffusers. We would also advise if the ratios were lower, to carry out tests to see if the lower ratio is acceptable and performance meets your approval. You could add some perfumer alcohol to help increase scent throw and boost performance. perhaps 3 to 5%.
What are we doing regarding the recent IFRA 49 changes?
Although we have been proactive and have already modified some of our fragrances. We will continue to work with our perfumers to determine which of the fragrances affected can be modified, without causing changes to the olfactory character of the oils or affect the usage in candles and melts. We may be forced to introduce a diffuser only fragrance, which will mean having to buy the candle/wax melt version. Or If possible, we will create a generic Modification that will be compatible for all products but this may be slightly different in character.
IFRA 49 Updates
IFRA 49 comes into effect as from 10th May 2022. We will continue to update the CLP documentation for IFRA 49 for any remaining fragrance oils in the coming weeks. As you will appreciate this is a mammoth task with our extensive range, so if you require anything immediately, please email [email protected]