The helpdesk of Bureau REACH supports companies with their obligations regarding Registration, Evaluation, Authorization and restriction of Chemicals (REACH) and Classification, Labelling, and Packaging (CLP). A key tool of the helpdesk is the website: www.chemischestoffengoedgeregeld.nl.
This website provides information on the REACH and CLP regulations, the 'Check wat u moet doen' tool and associated obligations, and a FAQ section. The helpdesk communicates the latest developments via LinkedIn. Companies can also ask additional questions directly to the helpdesk via the inquiry form. Additionally, they can request a telephone appointment.
In 2023, many questions were asked about recurring and new topics, such as:
- The newly imposed training requirement as of August 23, 2023, when working with diisocyanates following the restriction (restriction) (e.g., PUR foam).
- The integration of customs codes and REACH obligations.
- The new restriction on the use of microplastics.
- Where to find the phone number of the National Poisons Information Center (NVIC) for inclusion on the safety data sheet.
- Obligations related to the production and sale of (scented) candles.
Example question:
"I am considering selling homemade candles. These candles are made from pure local beeswax without additives or from rapeseed wax with possibly a little pigment. How can I find out if I comply with the legislation?"
An example answer to the above CLP question:
The basis of this answer is how to determine whether you comply with the CLP regulation. A CLP hazard label is required if the candles are classified as hazardous according to the CLP regulation. This may also be the case when substances of natural origin are present and classified as hazardous. However, beeswax and rapeseed wax are not classified as hazardous. The classification depends on the other substances in the candles. In your case, these are only the possible pigments.
If the pigments are also not classified as hazardous, then no CLP hazard label is required for the candles. You should check whether additional label information is required for a non-hazardous product according to the CLP regulation (see section 4.8.1 of the Guidance on Labeling and Packaging). If not, there is no obligation to affix a CLP label to the product. For labeling requirements for candles that are not classified as hazardous, you can find information on the following websites:
The candles may be classified as hazardous if, for example, fragrances were added. (Natural) fragrances and/or oils sometimes have a classification that, even at low concentrations, leads to a hazardous mixture (think of sensitization: H317, which usually occurs at 1%, or sometimes lower, leading to the same classification of the mixture). In that case, a CLP hazard label is required. For more information on classifying and labeling mixtures, see the mixture classification.
For candles classified as hazardous according to CLP, the required label elements can be found in section 3.2 of the Guidance on Labeling and Packaging. The Guidance also contains other information, such as where to place the label on the product (section 3.1) and exemptions from labeling requirements for small products (section 5.3).
Additionally, a product notification to Poison Centres Notification (PCN) and a Unique Formula Identifier (UFI) on a label are mandatory for mixtures (such as candles) that must be classified as hazardous according to CLP (at least 1 H-statement other than for environmental hazards). If your product is classified for physical (H2xx statements) and/or health hazards (H3xx statements), you are required to notify your product via the PCN portal. This obligation applies regardless of the volume you sell.
For more information on PCN notification: Steps for industry and for creating a UFI code: UFI Generator (europa.eu) Poison Centres Homepage (europa.eu)