Why CLP Compliance Matters. - Dayas Essence

Why CLP Compliance Matters.

ALL OF OUR PRODUCTS ARE CLP COMPLIANT
What is CLP?

CLP stands for Classification, Labelling and Packaging (CLP) Regulation

From 1 January 2021, the classification, labelling and packaging of chemicals placed on the market in Great Britain (England, Scotland and Wales) is regulated by the ‘Retained CLP Regulation (EU) No. 1272/2008 as amended for Great Britain’, known as GB CLP.

The Health and Safety Executive (HSE) is the GB CLP Agency and carries out certain CLP functions previously undertaken by the European Chemicals Agency (ECHA).

Makers of Candles and wax melts have a legal duty to understand the obligations and duties under GB CLP.

One of the main aims of CLP is to determine whether a substance or mixture displays properties that lead to a hazardous classification. The hazard classes in CLP cover physical, health, environmental and additional hazards.

CLP sets detailed criteria for the labelling elements: pictograms, signal words and standard statements for hazard, prevention, response, storage and disposal, for every hazard class and category. It also sets general packaging standards to ensure the safe supply of hazardous substances and mixtures. 

This is so that the end user (You) can look at the label and immediately see what or if any of the ingredients are present that you could be sensitive to.
ALWAYS store products out of reach of children and pets.
In the event of product ingestion, ensure you have the product ingredients with you when you seek medical advice. 
All candles, melts, diffusers and room sprays that contain fragrance oils or essential oils MUST have CLP, a warning sticker ISN’T a CLP.
All Daya’s Essence safety data sheets and CLPs are made for the concentrate amount that we use and have all been checked for these harmful hazard triggers, we adhere to all necessary protocol and practices to ensure our safety standards are the highest. 
SAFETY IS IMPERATIVE.
Wax is non-hazardous to health so you won’t see the wax used on a CLP
(Paraffin is NONE toxic.)    
People ask if wax melts and candles can be used around Cats / Dogs and other animals, as long as you melt in well-ventilated areas this is fine, each animal/person may smell the scent at a different level so this is down to preference! Animals are unique just like us, always consult a VET if ever unsure,  If you have birds and other smaller animals, use your home fragrance products in an area that’s a safe distance way.
The same ingredients or other ingredients might be toxic to aquatic environment, dispose wax in a safe way, never down a drain, or unsafely dumped.

So... What does a CLP look like?

 

CLP IS NOT GENERIC, A WARNING LABEL / SAFETY STICKER IS NOT CLP

 

Below are two examples.

The first is a safety sticker.

Example two IS a CLP sticker. CLP stickers rarely look the same. They may (but not always) contain a SIGNAL WORD. In this example the signal word is WARNING.

PICTOGRAMS are sometimes triggered as in our example (but again, not always), along with any triggered hazards, precautions, allergens and classifying ingredients. It is not uncommon for a CLP to look quite empty. For example you may come across a CLP with nothing on but the fragrance name, the words SDS available on request" and the manufacturers business information.

 

 

EXAMPLE ABOVE IS A CLP STICKER

IMAGES PROVIDED BY STICKY PRINT PIXELS

 

 

Signal Words

A signal word indicates the relative level of severity of a particular hazard. The label must include the relevant signal word in accordance with the classification of the hazardous substance or mixture: more severe hazards require the signal word ‘Danger’ while less severe hazards require the signal word ‘Warning’. Some CLP stickers don't require a signal at all. As with every aspect of CLP, it's hazard-specific.

 

Hazard Statements

The Hazard Statements are those that provide the consumer with a direct warning as to what the mixture may do – the nature of the hazard. If a Hazard Statement is triggered by a particular ingredient at a specific concentration, it MUST be included on the label, along with its relevant pictogram.

Some examples of Hazard Statements;

  • May cause an allergic skin reaction.
  • Harmful to aquatic life with long lasting effects.
  • Causes serious eye irritation.

Precautionary Statements

The Precautionary Statements are a set of instructions that advise the customer how to avoid or minimise the hazards that may be caused by the hazardous mixture.

Such as.

  • IF ON SKIN: Wash with plenty of soap and water.
  • Avoid release to the environment.
  • Wash hands and other contacted skin thoroughly after handling.

 

Hazard Pictograms (see more below)

A hazard pictogram is a pictorial presentation to communicate information on the hazard concerned the classification of a substance or mixture determines the hazard pictograms that have to be displayed on a label, Pictograms have a minimum size requirement. They can not be smaller than 1cm along each red line. Which is approximately 1.4cm from point to point left to right.

Product Name (eg, Black Raspberry Wax Melt)

This can be anything. You do not have to copy your oil supplier's fragrance name. After all, you're not selling their oil, you're manufacturing a brand-new product.

Product Identifier

This is your product name as above, but also the ingredients on the CLP/SDS that classified your product as hazardous. Not every fragrance oil will have classifying ingredients, and some suppliers add this to the "contains" section instead. The product identifier can be found in section 1.1 of your 10% SDS. Or, from a supplier's CLP template it's the ingredients listed next to the fragrance name. (example shown further down)

EUH208 (CONTAINS Section)

This is the list of sensitizing substances or allergens found in your product.

Manufacturer address and phone number (or in other words, YOUR vendors business details)

You MUST provide your customer with your address and phone number. Customers, by law, have the right to know who it is they are entering into a contract with. For CLP this info must be included on your label. There are no loopholes.

 

A LITTLE MORE INFO ON THE MOST COMMON PICTOGRAMS WE SEE ON WAX MELTS

 

 

The most common pictograms you're likely to see on a wax melt CLP are the GHS07 & GHS09. This doesn't mean that every CLP will contain a pictogram. It won't. Pictograms are only present if a particular hazard is triggered in the product to require a specific pictogram.

 

GHS07

 

  • The GHS07 (exclamation) pictogram signifies a hazard.

 

What does it mean?

This pictogram in melts, is most commonly linked to the H317 hazard: May cause an allergic skin reaction. Though it can signify other hazards too:

  • May cause respiratory irritation
  • May cause drowsiness or dizziness
  • May cause an allergic skin reaction
  • Causes serious eye irritation
  • Causes skin irritation
  • Harmful if swallowed
  • Harmful in contact with skin
  • Harmful if inhaled
  • Harms public health and the environment by destroying ozone in the upper atmosphere

 

Common products that might contain this pictogram are washing detergents, toilet cleaners & home fragrance products.

 

As well as hazards, this pictogram in particular will have precautionary statements depending on which hazard was triggered. These include:

  • If on skin: wash with plenty of soap and water
  • If in eyes: rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing.
  • Avoid breathing dust/fume/gas/mist/vapours/spray
  • Use only outdoors or in a well-ventilated area
  • If inhaled: remove victim to fresh air and keep at rest in a position comfortable for breathing
  • If swallowed: call a POISON CENTER or a doctor/physician if you feel unwell
  • Wear protective gloves/protective clothing/eye protection/face protection.
  • Do not eat, drink or smoke when using this product.

 

GHS09

  • The GHS09 (environment) pictogram means that the product is classified as hazardous to the environment.

 

What does it mean?

This pictogram in melts, is most commonly linked to the H411 hazard: Toxic to aquatic life with long lasting effects. Though it can signify other hazards too:

 

  • Very toxic to aquatic life with long lasting effects

 

Common products that might contain this pictogram are pesticides, biocides, petrol, turpentine and home fragrance products.

 

Precautionary statements we might see alongside this pictogram are:

  • Avoid release to the environment
  • Collect spillage

 

 

Toxic / harmful to aquatic life and what this means? 

CLP and the effects on aquatic life

We limit the emissions but many chemicals used today still end up in our environment and in lakes, rivers and oceans. Most chemicals cause no harm but not surprisingly, chemicals that are harmful to humans may also be harmful to the environment and to the animals that live in aquatic ecosystems.

How can products with the environment pictogram be disposed of safely?

Properly dispose of the product (wax) as hazardous waste – do not dump it down the drain, on the ground, or into any body of water.

Prevent the product (wax) from contaminating ground water, surface waters, and the sewer system.

Don’t pour your liquid wax down the sink or toilet, this WILL clog up the drains it will also contaminate the sewage system, dispose your liquid wax soaked up either by cotton wool or harden wax in the general waste bin.

Toxic to aquatic life DOESN’T mean whilst you melt your favourite scent you will harm your fish. 

Here are some common questions and answers:

Can I just print and give the customer the CLP information instead of attaching to the products?

Absolutely not, CLP must be attached to all products where its been handled, all products with CLPs required should be shown at point of sale and not on printed paper, if in the unlikely event the print out was to go missing, or liquid was spilt on this; the information would be hard to see, its a legal requirement the CLP has to be on the actual products.

A product doesn’t trigger any allergens, is a CLP still needed?

Yes a CLP is needed, certain oils wont trigger any allergens, but a CLP MUST still be provided in order to provide you the customer with the product identifier, hazard statement, precautionary statements and supplier identification details, SDS sheets should be available upon request to back this up.

I have been told that products below 125ml do not need to have CLP, is this true?

Sadly this is false.
You will hear constantly that CLP is not required for products of 125ml or less, however this is not the case. CLP is still required however certain items may be omitted; these exemptions can be the hazard and/or precautionary statements or pictograms which are normally present in normal circumstances.
If the product is too small for a CLP sticker (smallest size being 37mm round) you can use a piece of card attached with the CLP information on and fix to the product via string, or source the medicine bottle stickers where you can peel back bits of the sticker to view all information.
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