The CLP Regulations (Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures) is an EU law that aligns the European system with the Globally Harmonised System (GHS) developed by the United Nations. Its purpose is to ensure that hazards associated with chemicals are clearly communicated through standardised labelling and classification practices across all EU Member States.
CLP replaces the older Dangerous Substances and Dangerous Preparations Directives and works alongside the REACH Regulation (EC No 1907/2006) to ensure the safe use of chemicals, protect human health and the environment, and support free trade through consistent hazard communication.
CLP applies to all chemical substances and mixtures placed on the EU market. This includes candles, diffusers, personal care products and perfumes. It requires manufacturers and importers to:
- Classify substances and mixtures according to their hazards.
- Label them clearly and consistently using standardised elements.
- Package them safely.
What needs to be written on my CLP label?
The required CLP label elements can be found in Section 2.2 of the Safety Data Sheet (SDS). Your label must include, where applicable:
- Product identifier (trade name / product name)
- Supplier details (name, address, and emergency telephone number)
- Nominal quantity (net weight in g or volume in mL, unless shown elsewhere on the packaging)
- Hazard pictograms
- Signal word (“Warning” or “Danger”)
- Hazard statements (e.g., H317, H411)
- Precautionary statements (e.g., P102, P273, P501)
- Names of hazardous components contributing to the classification
- EUH208 statement — if applicable, see the dedicated section below
- UFI code — if applicable, see the dedicated section below
These elements must be clearly visible on the product label. For scented products such as candles, wax melts, diffusers, and sprays, correct labelling is mandatory when the final product is classified as hazardous.
EUH208: Allergen Labelling for Sensitising Substances
This is one of the most frequently overlooked elements on CLP labels for scented products, so it deserves its own section.
What is EUH208?
EUH208 is a supplemental hazard statement defined in Annex II of the CLP Regulation. It reads:
“Contains [name of sensitising substance(s)]. May produce an allergic reaction.”
It is required when a product contains one or more skin sensitising substances at concentrations that are too low to trigger full CLP classification (i.e. the H317 hazard statement), but still high enough to elicit a reaction in people who are already sensitised to that substance.
When does EUH208 apply?
The key thresholds are set out in Table 3.4.6 of Annex I to the CLP Regulation. The general rule of thumb is that the elicitation threshold is one-tenth (1/10) of the classification threshold:
| Sensitiser Category | Classification threshold (triggers H317) | EUH208 threshold (below classification but above this) |
|---|---|---|
| Skin Sens. 1B (generic) | ≥ 1.0% | ≥ 0.1% |
| Skin Sens. 1A (generic) | ≥ 0.1% | ≥ 0.01% |
| Substances with a Specific Concentration Limit (SCL) | At the SCL | At 1/10 of the SCL |
Practical example: If a fragrance ingredient is classified as Skin Sens. 1B, and your finished product contains it at 0.3% (below the 1.0% classification cut-off) your product will not carry H317. However, since 0.3% is above the 0.1% elicitation threshold, you must add EUH208 to the label naming that specific substance.
How does EUH208 interact with H317?
- If your product is already classified as H317, the sensitising substances are listed under the “names of hazardous components” section. In this case, EUH208 is not separately required for those same substances, but any additional sensitisers present above the elicitation threshold but below the classification threshold should still be listed via EUH208.
- If your product is not classified as H317 (non-hazardous), but still contains a sensitiser above the elicitation threshold, EUH208 is required on the label even though no other hazard elements are present. This means your product still needs a CLP label area even when it is otherwise non-hazardous.
EUH208 and the CLP Label Generator
Our interactive CLP Label Generator handles EUH208 automatically. When you enter the percentage of fragrance oil you will be using, the tool checks whether any sensitising ingredients in that fragrance cross the EUH208 elicitation threshold at your specific usage level. If they do, the EUH208 wording (including the names of the relevant substances) is included directly in the generated label output. You do not need to look this up separately.
⚠️ Important: EUH208 is determined by what is in your entire final product formulation, not just the fragrance oil. If you combine multiple raw materials, each of them may contribute additional sensitising substances. The tool covers the fragrance oil’s contribution — you remain responsible for assessing any other ingredients in your formula.
UFI Number: What You Can and Cannot Do
The UFI (Unique Formula Identifier) is a 16-character alphanumeric code that links a hazardous mixture to a registered Poison Centre Notification (PCN). From January 1, 2025, the UFI is mandatory for all hazardous consumer and professional-use mixtures sold in the EU.
If you are using one of our fragrance oils and the final product you create is classified as hazardous under CLP, then:
✅ You must generate your own UFI and submit your own PCN for that specific mixture. Our UFI cannot be reused because the newly created product is considered a new mixture.
This applies if you:
- Create a candle, diffuser, wax melt, spray, or any other finished product using our oils
- Combine our fragrance oil with other hazardous substances (e.g., solvents, thinners)
- Resell, repackage, or rebottle our fragrance oil
- Mix more than one fragrance oil
- Or otherwise change the hazard profile of the final product
If your final product does not trigger any CLP classification (i.e. it is non-hazardous based on your usage level):
❌ No UFI declaration is required on the label, and no PCN submission is required.
However, even a non-hazardous product may still require a CLP label if EUH208 applies. See the section above.
📖 For a full breakdown of UFI requirements, see our blog post: New UFI Declaration Requirements for Scented Products sold in the EU
SDS, IFRA & Allergen Declarations
All regulatory documents (Safety Data Sheets (SDS), IFRA Certificates, and Allergen Declarations) are available for download on each product page under the “Related Documents” tab.
- Our SDS documents describe the fragrance oil as a raw material at 100% concentration. Section 2.2 of each SDS lists the label elements for the raw material itself; you use this data as an input for calculating the classification of your finished product.
- IFRA Certificates specify the maximum safe usage level per application type (e.g., candles, soaps, perfumes).
- Allergen Declarations list the sensitising substances present in the fragrance oil above the required thresholds. Use these to assess whether EUH208 applies to your finished product.
- Extended Allergens Declarations — we are progressively introducing this new document for use in cosmetic applications. It covers the expanded EU allergen list under Regulation (EU) 2023/1545 and will eventually replace the classic 26-allergen declaration. See our Fragrance Regulatory Updates post for more detail.
📩 Contact us if you require a Certificate of Analysis for batch tracking.
EU Cosmetic Allergen Labelling (Regulation (EU) 2023/1545)
This is a separate requirement from CLP and applies specifically to finished cosmetic products (leave-on and rinse-off products such as creams, lotions, perfumes, soaps, shower gels, etc.).
The EU has significantly expanded the list of fragrance allergens that must be declared on cosmetic product labels:
- New cosmetic products placed on the EU market must comply with the extended allergen list by 31 July 2026.
- All existing cosmetic products must be updated or withdrawn by 31 July 2028.
If you use our fragrance oils in cosmetics, your finished product labels need to reflect all allergens from the new expanded list that are present above the applicable thresholds. Our Extended Allergens Declaration documents are designed to support you with this. Contact us if you need a document for a specific product urgently.
📘 Note: Cosmetic products are exempt from CLP classification and labelling requirements. Allergen disclosure in cosmetics is governed by the Cosmetics Regulation, not CLP. The UFI/PCN system (Annex VIII to CLP) does not apply to finished cosmetics either — these are notified via the Cosmetic Products Notification Portal (CPNP).
Using Perfumedom’s CLP Label Generator
The Perfumedom CLP Label Generator is our free interactive tool that produces CLP label guidance for any of our fragrance oils based on the percentage you plan to use in your final product.
Most suppliers hand you an SDS and leave the rest to you. Even if they do provide, they chose to focus on the design aspect of a label rather than data accuracy and detailed compliant assessments. We built this tool because correct CLP labelling is not optional, and working it out manually (cross-referencing SDS data, concentration thresholds, EUH208 substance lists, and application-specific limits) is genuinely time-consuming and error-prone, especially if you are not doing it every day.
The generator needs at least 2 elements to produce a CLP. The fragrance name/code and the usage percentage. The tool takes care of all the rest by:
- Calculating whether your fragrance level triggers CLP classification
- Showing the applicable hazard pictograms, where required
- Displaying the correct signal word (“Warning” or “Danger”), where applicable
- Listsing all relevant H-statements (e.g. H317, H319, H412)
- Including EUH208 allergen wording where applicable — automatically, based on your usage level
- Distinguishing clearly between full hazard classification and supplemental EUH208-only labelling
- Covering all major application types (candles, room sprays, reed diffusers, and more)
- And all that available in 21 languages!
The CLP Generator uses SDS-based fragrance data from our manufacturers, so the outputs are grounded in the same documentation we provide in the “Related Documents” tab of each product page. It is designed specifically for Perfumedom fragrance oils.
Built on the ECHA C&L Inventory. Not guesswork
What sets the Perfumedom CLP Label Generator apart technically is its direct connection to the ECHA Classification & Labelling (C&L) Inventory – the official EU database maintained by the European Chemicals Agency that contains hazard classification and labelling data for hundreds of thousands of chemical substances. The database draws on both EU-harmonised classifications (Annex VI of the CLP Regulation) and industry-submitted notifications from REACH registrations, and is updated continuously.
When you enter your fragrance percentage, the generator does not rely on simplified lookup tables or manually maintained spreadsheets. It queries this authoritative source across hundreds of CAS numbers (the individual chemical identifiers for each ingredient in the fragrance oil) to retrieve their current hazard classifications, concentration thresholds, and sensitisation data. This means the hazard statements, pictograms, signal word, and EUH208 output you receive reflect the actual regulatory record for each substance, not an approximation of it.
The result is a level of classification accuracy and chemical coverage that generic online CLP tools, most of which rely on static, manually curated substance lists, simply cannot match. For fragrance formulations in particular, which can contain dozens of individual ingredients each with their own CLP status, this depth of data is not a technical nicety. It is what makes the output reliable enough to actually use on a label.
The tool includes a Product Information step where you can enter your business and product details directly into the label. These fields are optional (you can skip them for speed and add them later in your design process), but they are required by regulation for a complete and compliant label:
- UFI (if your product is classified as hazardous)
- Product identifier (trade name) and batch number
- Company name, address, and emergency telephone number
- Nominal quantity (net weight in g or volume in mL)
⚠️ The CLP Label Generator is a practical labelling aid, not a substitute for professional regulatory advice. It covers the CLP contribution of the fragrance oil at your stated usage level. If your final product contains other ingredients, you are responsible for assessing their combined impact on classification and labelling.
Quick Reference: Do I Need a CLP Label?
| Situation | CLP label required? | UFI required? | EUH208 required? |
|---|---|---|---|
| Product is classified as hazardous (H-statements present) | ✅ Yes | ✅ Yes | Only if additional sensitisers are present below H317 threshold |
| Product is not classified as hazardous, but contains a sensitiser above the EUH208 threshold | ✅ Yes (for EUH208) | ❌ No | ✅ Yes |
| Product is not classified and no sensitisers above EUH208 threshold | ❌ No | ❌ No | ❌ No |
| Finished cosmetic product | ❌ No (CLP exempt) | ❌ No (CPNP instead) | Via Cosmetics Regulation, not CLP |
Further Reading
- 📄 New UFI Declaration Requirements for Scented Products sold in the EU
- 📄 Fragrance Regulatory Updates in 2026
- 📄 Supplier Obligations vs. Customer Responsibilities
- 📄 What Documents Do I Need for Fragrance Oils?
Disclaimer: The information provided here is accurate to the best of our current knowledge and is offered in good faith. It reflects the classification and regulatory contribution of the fragrance oil as a raw material. The ultimate legal responsibility for classifying, labelling, and notifying the final product lies with the person or business placing that product on the market. You must assess your full formulation using all available data to determine your obligations under the CLP Regulation and any other applicable legislation. When in doubt, consult a qualified regulatory expert.