The regime split soap and candle sellers keep confusing — when a CLP hazard label applies, when an INCI ingredient list does instead, and where lye handling fits in.
CLP and cosmetics law are two different regimes, and a candle or a bar of soap almost never sits under both. Which one applies depends on what your product actually is, not on what you call it in your shop.
If your soap is meant to clean skin, it is a cosmetic under Regulation (EC) No 1223/2009, the same regulation that governs lotions and balms. Cosmetics are carved out of CLP labelling for the finished product (Regulation (EC) No 1272/2008, Article 1(5)(d)) because they're covered instead by cosmetics law — so a cured bar of skin soap gets an INCI ingredient list, not a hazard pictogram.
Two things still bring CLP into a soap maker's life. First, sodium hydroxide (lye) is a CLP-classified corrosive (Skin Corr. 1A, H314) while you're working with it, and your supplier's safety data sheet governs how you store, handle and label that raw material during production — even though it disappears as lye once saponification finishes. Second, a bar sold as a household cleaner rather than a skin product — a laundry bar, a dish bar — is a detergent, not a cosmetic, and CLP hazard labelling can apply to it.
Candles aren't cosmetics, so they don't get the CLP exemption. Once your fragranced wax is a "mixture" under CLP, its labelling depends on which skin-sensitising substances are in it and at what concentration in the finished candle — not in the neat fragrance oil you bought.
CLP's generic thresholds for skin sensitisers: a substance in the stronger Category 1A group triggers full classification around 0.1% and the lighter allergen statement around 0.01%; a substance in the broader 1B / generic Category 1 group triggers classification around 1% and the statement around 0.1%. Below both, nothing is required. A fragrance supplier's own specific concentration limit for their exact blend overrides the generic number.
This is separate from the voluntary EN 15493 family of candle-safety standards (burn behaviour, soot, wick), which many retailers ask for but which is not a CLP requirement — don't tangle the two on one label.
Do the maths on the fragrance's constituents, not the oil as sold: an oil that's 2% of your candle wax by weight contributes each of its own listed skin sensitisers at 2% of their concentration in the oil. Your fragrance supplier's safety data sheet (sections 2 and 3) lists which constituents carry a skin-sensitisation classification and at what percentage — scale that number down, not the finished-candle load quoted on a marketing sheet.
None of this is legal advice. CLP thresholds and classifications are updated periodically, so check the current consolidated text of Regulation (EC) No 1272/2008 on EUR-Lex and your supplier's latest safety data sheet before you print a label.
Educational, not legal or safety advice. Check current official sources before you act on it.
Batch records, lot numbers, ingredient labels and IFRA checks are built into the workshop, so the guide you just read becomes a habit, not a chore.