Guides / Fragrance load
Does changing the fragrance load change the CLP label?
Published 21 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.
It can. A CLP label states the classification of the mixture as you sell it, and the classification depends on the concentration of each hazardous substance in it (Article 11(2)). Your supplier's document classifies the fragrance at a stated percentage; at a different percentage the same fragrance can cross a limit in either direction, adding a hazard or dropping one. So the answer is: use the classification for the load you actually pour. Most suppliers give data at more than one load, and if yours does not, ask.
Why the percentage decides
Article 4(1) puts the duty to classify a mixture on the person placing it on the market, and Article 4(6) lets a downstream user rely on a classification derived by someone up the chain "provided that they do not change the composition of the substance or mixture". A candle at 8 % fragrance and a candle at 10 % fragrance are different compositions. The classification criteria in Annex I are limits on the concentration of each classified component in the finished product, and for the hazard that touches most scented wax they read:
| Sensitiser in the fragrance is classified as | Mixture classified Skin Sens. 1, H317 (Table 3.4.5) | EUH208 "Contains..." only (Table 3.4.6) |
|---|---|---|
| Skin sensitiser category 1 or 1B | at or above 1,0 % | at or above 0,1 % |
| Skin sensitiser sub-category 1A | at or above 0,1 % | at or above 0,01 % |
Those percentages are of the candle, not of the oil. Take a fragrance oil that contains a category 1 sensitiser at 12 % of the oil. At a 10 % load that substance is 1,2 % of the candle, above the 1,0 % limit: the label carries the GHS07 pictogram, "Warning" and H317. At an 8 % load it is 0,96 % of the candle, below 1,0 % but above 0,1 %: no pictogram, no signal word, and instead the line "EUH208 Contains (name). May produce an allergic reaction." Two points of fragrance load moved the product between two different labels. The same arithmetic runs for the aquatic hazards, whose limits and summation rules sit in section 4.1 of Annex I.
The regulation's own tolerance table
CLP does contain a rule about how much a concentration may move before the earlier evaluation has to be redone. Article 15(2)(a) requires a new evaluation of a hazardous mixture when the initial concentration of a hazardous constituent changes by as much as the variation in Annex I Table 1.2, or more ("at or above the limits" of the table):
| Initial concentration of the constituent | Permitted variation |
|---|---|
| 2,5 % or less | plus or minus 30 % |
| more than 2,5 % up to 10 % | plus or minus 20 % |
| more than 10 % up to 25 % | plus or minus 10 % |
| more than 25 % up to 100 % | plus or minus 5 % |
The variation is relative: a constituent at 1,2 % of the candle may move between roughly 0,84 % and 1,56 % before Article 15(2)(a) demands a fresh evaluation. Read that against the worked example above and the limit of the rule is clear. Moving the load from 10 % to 8 % changes every constituent by 20 %, inside the tolerance for constituents at 2,5 % or less, and the example still crossed the 1,0 % line. Table 1.2 says when the person who evaluated the mixture must evaluate it again; it does not say a smaller change can never alter the label. For a maker working from a supplier's document, the practical rule is simpler: match the load to the load the document states, or get a document for yours.
Down as well as up
The elements in Article 17(1)(d) to (g) are required "where applicable". A pictogram or hazard statement for a hazard the product does not have is not a safe extra; it is a statement inconsistent with the classification. So a lower load can and should remove elements when the supplier's data at that load no longer supports them, and the label should be rebuilt rather than left as it was.
How quickly the label must change
Article 30 as it stands in Great Britain, and in the EU and Northern Ireland until the end of 2027, requires the label to be updated "without undue delay" after a change of classification where the new hazard is more severe or new supplemental information is required, and within 18 months for other changes. From 1 January 2028 the EU and Northern Ireland text, as replaced by Regulation (EU) 2024/2865, sets an outer limit: a new hazard class, a more severe classification or new supplemental information must reach the label without undue delay and at the latest six months after the results of the new evaluation are obtained, and any other change within 18 months. That replacement was due on 1 July 2026 until Regulation (EU) 2025/2439 moved it. In practice a maker pours the new load with the new label; these deadlines matter for stock already made.
Two oils in one candle
A load change is the simple case: the same fragrance, a different percentage. Blending two oils is a different composition altogether and no supplier document covers it; see CLP labels for a custom blend of fragrance oils.
Related questions
My supplier only gives CLP data at 10 %. Can I use it for a 6 % candle?
The document tells you what it covers, and 10 % is not 6 %. The regulation's own tolerance table (Annex I Table 1.2) allows a hazardous constituent's concentration to vary by less than 30 % of its value, when that constituent is at 2,5 % or less of the product, before the earlier evaluation must be redone; a move from 10 % to 6 % is a 40 % change in every constituent, which is outside it. Ask the supplier for data at your load. Most publish it at several loads or provide a calculator, because this question is routine.
Can a lower fragrance load ever add a hazard?
Not through concentration alone. The classification limits in Annex I are thresholds: less of a substance cannot take it over a limit it was under. A lower load can only keep hazards or drop them. A higher load can add them, and that is the direction to be careful in.
Do I need a new UFI when I change the load?
In Great Britain there is no UFI. In the EU and Northern Ireland, Annex VIII, Part B, section 4.1 requires a submission update before the changed mixture is placed on the market when the classification for health or physical hazards changes, or when a component's concentration moves beyond the range given in the original submission, and Part A, section 5.1 says when a change in composition needs a new UFI.
Tell me if this answer changes
The concentration limits in Annex I move when the EU adapts CLP to technical progress, and the EU rewrote the label-update deadlines in July 2026. If either changes, we will email you.
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Sources
- Regulation (EC) No 1272/2008 (CLP), consolidated 01.07.2026: Articles 4(1), 4(4), 4(6), 11(2), 15(2), 17(1) and 30; Annex I, section 1.1.3.6 with Table 1.2, section 3.4.3.3.1 with Tables 3.4.5 and 3.4.6; Annex II, section 2.8; Annex VIII, Part A section 5.1 and Part B section 4.1
- Regulation (EC) No 1272/2008 as it applies in Great Britain (assimilated law): Article 30 (unamended), Annex I Table 1.2 and Tables 3.4.5 and 3.4.6, legislation.gov.uk, text current to 21 May 2026
- Regulation (EU) 2024/2865, Article 1 point (14) (Article 30 as replaced), read from EUR-Lex on 21 September 2026
- Regulation (EU) 2025/2439, Article 1(c): Article 2(3a) of Regulation (EU) 2024/2865 (Article 1 point (14) applies from 1 January 2028), read from EUR-Lex on 25 September 2026
The documents this answer rests on. A labelling reference, not legal advice; you remain responsible for your product's labelling.