Fragranced Products Case Study

Fragranced products are required to be classified, and if hazardous, labelled according to the Classification, Labelling and Packaging (CLP) Regulation, unless covered by other sectoral legislation. Gill Pagliuca looks at what types of hazards may be present in these products, what sort of information may be needed for classification, and at some of the issues that suppliers may face when labelling these products.
Many suppliers of fragranced products are not aware that their products are in scope of the CLP Regulation, and may be classified as hazardous and consequently require labelling. This may be because they deal primarily with products regulated under other legislation such as foods and cosmetics and only supply a few household items such as fragranced candles or room sprays. Items such as candles are also often not thought of as chemical products, however, under both the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and CLP Regulations they are considered to be a combination of a carrier article (the wick) and a mixture (the wax, fragrance, colouring and any
CLP labelling rules generally specify the use of complicated chemical names (the EC or IUPAC names) for preference, though other internationally recognised names are also permitted such as the INCI names used for cosmetics and toiletries. Is it better for consumer recognition and understanding if a hazardous component is identified as the natural fragrance, for example, lavender oil, or is it better to identify the actual hazardous component(s) of the oil, such as linalool? The purpose of a label is to communicate, so careful consideration should be given to not just regulatory compliance but also to selecting names that consumers are most likely to be aware of when identifying products that they may be sensitive