A Safety Data Sheet and a CLP label are not the same document — and the difference matters, because most candle makers never have to hand an SDS to the people who buy their candles. Here's when a Safety Data Sheet is actually required, and when the label on the pot is enough.

What a Safety Data Sheet is

A Safety Data Sheet (SDS) is the standardised, 16-section document that carries a product's hazard, handling, storage, first-aid and disposal information down the supply chain. In the EU and UK it's governed by REACH Article 31 (Regulation (EC) No 1907/2006), and its format is set by Annex II — updated by Commission Regulation (EU) 2020/878, which has been mandatory since 1 January 2023. Since that update, Section 1 of an SDS for a hazardous mixture also has to carry the product's UFI.

The key thing to hold onto: an SDS is written for professional and industrial users — the people who handle a product at work. It is not a consumer document.

SDS vs the CLP label: who each one is for

This is where most of the confusion lives. The two documents do different jobs for different audiences:

  • The CLP label is the consumer-facing one — the hazard warning printed on the candle itself, so the person who buys it knows how to use it safely.
  • The SDS is the business-facing one — a detailed technical file for a professional who receives the product as part of their work.

So the real question isn't "is my product hazardous?" — it's "who am I supplying it to?"

The short answer for most candle makers

If you sell finished candles to consumers — at a market, through your own webshop, or in a shop that sells them on to the public — you generally do not have to provide a Safety Data Sheet to the buyer. REACH specifically exempts supply to the general public: as long as the product carries enough information to be used safely (that's what the CLP label is for), no SDS is owed to the consumer.

For a hazardous candle sold to the public, the safety net is therefore the CLP label plus — where the classification requires it — a poison centre notification. Not an SDS.

When you do need to provide one

The duty appears the moment you supply to a business rather than a consumer. If you sell your candles, wax melts or diffusers to another company — a wholesaler, a retailer buying stock, a white-label client — and the product is classified as hazardous, you must provide an SDS with the first delivery, in the language of the destination country, free of charge.

There's a second trigger worth knowing: even a product that isn't classified as hazardous can have an SDS requested by a business customer in certain cases — for example, a mixture that contains a hazardous ingredient above a set threshold. A trade buyer can ask, and if they do, you have to supply.

The SDSs you can't ignore — your raw materials

Even if you never sell to a single business, you're already on the receiving end of this system. Your fragrance oil and wax suppliers are legally obliged to give you an SDS for what they sell you, because you're a professional user buying their hazardous mixtures.

Those inbound SDSs are the most important documents in your workshop: Sections 2 and 3 are where the classification, the H-phrases, the allergens and the concentrations come from — the exact data you need to build your own CLP label, work out your EUH208 allergen line, and file a poison centre notification. Reading your suppliers' SDSs isn't optional; it's where compliance starts.

Diffusers cross the line more often

One reason to single out reed diffusers: their base is a solvent, and solvents are more hazardous than wax. A diffuser liquid can pick up flammability, aspiration and skin-sensitiser classifications that a solid candle never does — which makes a diffuser more likely to be a classified mixture, and therefore more likely to need a Safety Data Sheet the moment you sell it into a trade channel.

Where Molekule fits

Molekule reads the SDSs your suppliers send you, pulls out the classification and composition, and turns them into your product's CLP label, allergen line and poison centre notification — and, when a trade customer needs one, generates a compliant Safety Data Sheet for your finished product. One set of inputs, every compliance document out the other end.