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Do candles at craft fairs or as gifts need a CLP label?

Published 22 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.

Yes, when the candle is classified as hazardous or needs the EUH208 line. Supplying it free of charge is still placing it on the market. Article 2(18) of CLP defines placing on the market as "supplying or making available, whether in return for payment or free of charge, to a third party", and Article 4(4) requires a classified mixture to be labelled and packaged in accordance with the regulation before that happens. A stall at a fair, a gift with an order, a sample handed out and a raffle prize are all supply to a third party. The label goes on the packaging that contains the candle, and for a container candle that is the jar. GB CLP carries the same text. A candle that is not classified but contains a sensitiser at or above the limit in Annex I, Table 3.4.6 still needs a label in both EU and GB CLP: the EUH208 line of Annex II, section 2.8, with the product identifier and the supplier's name, address and telephone number (Article 25(6)).

Why "free" does not change the answer

Makers often assume that CLP is about selling. It is about supply by anyone acting in the course of a business. The regulation's definition of placing on the market names both possibilities, "whether in return for payment or free of charge", and the duties in Article 4 attach to suppliers, who under Article 2(26) are the manufacturers, importers, downstream users and distributors placing the mixture on the market. A sample at a fair reaches a member of the public exactly as a sold candle does, and reaches someone who has read nothing about it, which is the situation the label exists for.

Where the label goes on a candle

Article 31(1) puts the label on "the packaging immediately containing the substance or mixture", and Article 2(36) defines packaging as the receptacles containing it. For candles that resolves simply:

• Container candles. The jar, tin or glass is the packaging. A label on the base or the side of the container satisfies Article 31(1), and printing the elements on the container itself is allowed by Article 31(5). Pictograms keep their 10 x 10 mm floor, so a small tin may need the label on its side or on a tag and outer pack under Annex I 1.5.1.
• Pillar candles, tapers and melts. The wrap, sleeve, box or bag is the packaging and carries the label. A band or a swing tag that does not contain the candle is not packaging; a band that holds a sleeve closed is part of it.
• A box of several. Each inner pack carrying a classified mixture is labelled, and the box is outer packaging under Article 33(2), labelled unless it lets the inner labels be clearly seen. The placement page works through the cases.

Selling without packaging

The regulation has one provision for hazardous mixtures supplied to the general public without packaging, Article 29(3), and it applies only to the mixtures listed in Part 5 of Annex II, which are not candles. There is no unpackaged route for a classified candle: the label duty and the packaging duty in Article 4(4) run together, so a candle that is classified is supplied in something that contains it and carries the label. For a pillar candle at a fair that is a sleeve or a box, and the plain practical answer is that the sleeve is also where the customer reads the burn instructions.

What the packaging must not be

Article 35(2) applies to packaging supplied to the general public: no shape or design "likely to attract or arouse the active curiosity of children or to mislead consumers", and no "presentation or a design used for foodstuff or animal feeding stuff or medicinal or cosmetic products, which would mislead consumers". A classified candle in a cupcake case, a melt in a sweet wrapper or a wax bar in a chocolate-bar sleeve is the situation that sentence exists for, and the popularity of the format at fairs does not change the text.

Fairs and the rest of the label law

CLP is the hazard label. The elements it requires, name, address and telephone number of the supplier among them, are the same on a stall as in a shop; there is no fair exemption and no small-batch exemption in the text. The supplier is you, whether or not the transaction is a sale, and the address page covers what that means for a maker working from home.

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