Guides / Label placement on melts

Where does the CLP label go on wax melts?

Published 21 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.

On the packaging that immediately contains the melts, firmly affixed or printed, readable when the pack sits the normal way up. That is Article 31(1) of CLP, with Article 31(5) allowing the elements to be printed on the packaging itself instead of on a sticker. For a clamshell, that is the clamshell. For melts in a bag inside a box, it is the bag, and the box needs the label too unless the bag's label can be clearly seen through it (Article 33(2)). When a pack is too small or the wrong shape for a full label, the elements can go on a tie-on tag or on the outer packaging, with a minimum set kept on the inner pack (Article 29(1), Annex I 1.5.1). GB CLP carries the same text.

The immediate-packaging rule

Article 31 is short and specific. Labels are "firmly affixed to one or more surfaces of the packaging immediately containing the substance or mixture" and must be "readable horizontally when the package is set down normally" (31(1)). The colour and presentation of the label must make the hazard pictogram stand out clearly (31(2)). The elements must be clearly and indelibly marked, stand out from the background, and be of a size and spacing that is easily read (31(3)). A separate label is not required when the elements are shown clearly on the packaging itself (31(5)), so a printed clamshell sleeve or a printed bag is fine, and the same rules apply to that printing.

Boxes, bags and gift sets: inner and outer packaging

Article 33(2) covers the common maker case, a package with an outer and an inner packaging and no transport-of-dangerous-goods labelling: "both the outer and any inner packaging, including any intermediate packaging, shall be labelled in accordance with this Regulation. However, if the outer packaging permits the inner or intermediate packaging labelling to be clearly seen, the outer packaging need not be labelled." Applied to melts:

• Clamshell only. The clamshell is the immediate packaging. One label, on it.
• Bag inside a box. The bag carries the label. The box carries one too, unless the bag's label is clearly visible through the box (a window, or a clear box).
• Individually wrapped melts in a gift box. Each wrap is an inner packaging containing the mixture, so each needs the label or, if the wrap is too small, the tag or outer-packaging route below. The box is outer packaging under 33(2).
• Several scents in one box. Each scent is its own mixture with its own classification; each inner pack carries its own label. The box needs labelling for each unless the inner labels are clearly seen.

Too small for the full label: tags and outer packs

Article 29(1) applies where the packaging "is either in such a shape or form or is so small that it is impossible to meet the requirements" of Article 31 for a label; the EU text, since 1 July 2026, adds "in the languages of the Member State in which the substance or mixture is placed on the market". It sends you to Annex I, section 1.5.1. In the EU text as reworded from 1 July 2026, the label elements may then be provided on a tie-on tag or on an outer packaging (1.5.1.1); the GB text also lists a fold-out label as a third option here. Either way, the inner packaging must still carry a minimum set (1.5.1.2):

The address, the hazard and precautionary statements and the nominal quantity are the elements that may move to the tag or outer pack. Since 1 July 2026 an EU label may also be a fold-out label in the ordinary case, not only for small packs (Article 31(1) and Annex I 1.2.1.6, which set out what the front, inside and back pages carry); a single-language maker label rarely needs one.

Packs up to 125 ml: which statements may be dropped

Article 29(2) allows the label to be reduced in accordance with Annex I 1.5.2 where the full information cannot be provided even by the tag or outer-pack route. Section 1.5.2.1 applies where "the contents of the package do not exceed 125 ml", and for the categories a scented melt is likely to carry it says:

Pictograms and the signal word stay in every case above. Because skin sensitisation is the classification most scented wax carries, the practical effect is smaller than makers hope: H317 and its precautionary statements are on the label however small the pack.

Size and layout of the elements

• Pictograms are a square set on a point, a black symbol on a white background with a red frame wide enough to be clearly visible (1.2.1.1, 1.2.1.2). Each covers at least one fifteenth of the minimum surface area of the label given to the Article 17 information, and at least 1 cm² (1.2.1.3).
• Minimum dimensions for a package not exceeding 3 litres (Table 1.3): the label, if possible, at least 52 x 74 mm; each pictogram not smaller than 10 x 10 mm and, if possible, at least 16 x 16 mm.
• Together. The pictograms, signal word, hazard statements and precautionary statements are located together (Article 32(1)), and the supplemental information, EUH208 and any UFI, sits with them (32(4)).

EU and Northern Ireland from 1 January 2028: font size and colour

Regulation (EU) 2024/2865 adds formatting rules to Annex I for products placed on the EU market. They were due from 1 January 2027; Regulation (EU) 2025/2439 moved them to 1 January 2028, and a label may follow them earlier. Table 1.3 gains a minimum font size: an x-height of at least 1,2 mm for a package not exceeding 0,5 litres and 1,4 mm for one up to 3 litres. A new section 1.2.1.5 requires the label text to be printed in black on a white background, in a single easily legible sans-serif font, with line spacing of at least 120 % of the font size. The Commission has proposed simplifying these rules before they apply (COM(2025) 531, still before the Parliament and the Council), so the details may change. Great Britain has adopted none of this. Our tool will apply the EU and Northern Ireland rules from the date they apply; until then the colour and font choices in the designer remain yours.

Related questions