Guides / Renaming the fragrance

Can I rename the fragrance on a CLP label?

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

Yes. The product identifier for a mixture is "the trade name or the designation of the mixture" (Article 18(3)(a)), and the mixture on the label is your candle, so the name is yours to choose. A candle poured with a fragrance sold as "Apple Cinnamon" can be labelled "Apple Pie". What you cannot rename are the substances that contribute to the classification: Article 18(3)(b) requires those by their chemical identity, copied from your supplier's document. GB CLP carries the same text.

The two halves of the product identifier

Article 18(3) says the product identifier for a mixture consists of both of the following: (a) the trade name or the designation of the mixture, and (b) the identity of all substances in the mixture that contribute to its classification for acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitisation, specific target organ toxicity or aspiration hazard. Where that produces several names, a maximum of four suffices unless more are needed to reflect the nature and severity of the hazards, and the names chosen identify the substances primarily responsible for the major health hazards. From 1 January 2027 the EU list in (b) also covers substances that are persistent, bioaccumulative and toxic, very persistent and very bioaccumulative, persistent, mobile and toxic, very persistent and very mobile, or endocrine disruptors (Regulation (EU) 2024/2865); Great Britain keeps the shorter list.

Half (a) is a name. Half (b) is chemistry. Renaming touches only the first. The sensitisers named under EUH208 (Annex II 2.8) are the same kind of fixed text: the statement is "Contains (name of sensitising substance)", with the substance's name in it.

Names the regulation forbids

The freedom to name has one limit that applies before a range is printed. Article 25(4): statements such as "non-toxic", "non-harmful", "non-polluting", "ecological" or any other statements indicating that the mixture is not hazardous, or that are inconsistent with its classification, "shall not appear on the label or packaging". A product name is on the label. A candle classified for skin sensitisation cannot be called "Harmless" or "Pure and Non-Toxic", and a scent name that implies the product is safe to breathe or handle sits on the wrong side of the same line. Descriptive and evocative names are fine; claims of safety are not.

Keep the supplier's name for your records

Nothing requires the supplier's scent name on the label, but everything about your label traces back to that supplier's document at that load. Keep the oil's trade name, its batch number and the classification document with each product's design, so that when a supplier changes a formulation, and they do, you can see which labels it touches. If you also write a safety data sheet for a product, for shops or wholesale, Article 18(1) requires the identifier on the label to be the same as the one used on the sheet.

UFI and the name (EU and Northern Ireland)

A UFI is tied to the composition of the mixture, not to its name: Annex VIII, Part A, section 5.1 requires a new UFI when the composition changes in defined ways, and says nothing about names. So "Apple Pie" and the supplier's "Apple Cinnamon" candle, if they are the same formulation at the same load, share one UFI. What renaming does trigger is an update to the poison-centre submission: Part B, section 4.1 lists "when the mixture product identifier or the UFI has changed" as a condition for providing a submission update before the changed mixture is placed on the market. In Great Britain there is no UFI and no submission, so a rename there is only a label change.

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