Beware of those who say that if you use their fragrances you don't need to register the UFI code

 

In the artisan candle sector, the following phrase is often heard: “If you use our fragrances below a certain percentage, the UFI code is not needed.”

Is this really true?

To clarify this point, I asked ChatGPT some questions on February 26, 2026, trying to understand what European legislation truly stipulates.

Below you will find a summary of the responses, clearly organized.

1. If I produce scented candles, do I need a UFI code?

In most cases, yes.

The UFI (Unique Formula Identifier) code is a 16-character code required by CLP Regulation (EC) No. 1272/2008 to identify hazardous chemical mixtures.

It serves European poison centers to know the composition of a product in case of an incident.

If someone ingests or comes into contact with a substance contained in the product, medical personnel can enter the UFI into the European system and view the declared composition.

Why scented candles are often subject to the obligation

An unscented candle normally does not require a UFI.

A scented candle, however, almost always contains:

• fragrances

• essential oils

• aromatic solvents

• perfume allergens

Many of these substances are classified as:

• skin sensitizers

• irritants

• hazardous to the aquatic environment

When the final mixture is classified according to CLP, the UFI code becomes mandatory.

 

 

2. Is it true that if the fragrance is below a certain percentage, the UFI is not needed?

This statement is only partially correct.

CLP regulations do not consider the total percentage of fragrance, but rather the classification of the final mixture.

The correct question is not:

❌ “How much perfume do I use?”

but:

✔ “Is the finished candle classified as hazardous?”

If the mixture does not receive any hazard classification, the UFI is not necessary.

 

The point that causes the most confusion

Thresholds do not apply to the fragrance as a whole.

They apply to individual hazardous substances contained in the fragrance.

Real example:

A fragrance may contain substances such as:

• Linalool

• Limonene

• Citral

• Eugenol

Many of these are classified as skin sensitizers or hazardous to the aquatic environment.

If one of these substances exceeds the thresholds set by CLP in the final mixture, the candle becomes legally classified.

And when a mixture is classified → the UFI becomes mandatory.

 

3. To understand if the UFI is needed, do I have to study the SDS?

Yes, but simply looking at it superficially is not enough.

To correctly assess the situation, at least the following must be analyzed:

Section 2 — Hazard Identification

Section 3 — Composition

Then, the actual concentration of substances in the candle must be calculated.

Simplified example:

• Linalool in the fragrance → 3%

• Fragrance used in the candle → 6%

Final concentration:

3% × 6% = 0.18%

If the CLP threshold for that substance is 0.1%, the mixture becomes classified.

 

Another little-known problem

In CLP, the principle of additivity exists.

This means that similar substances can sum up.

Example:

• Linalool → 0.05%

• Citral → 0.04%

• Eugenol → 0.03%

Total sensitizers = 0.12%

Even if each substance is individually below the threshold, the sum can trigger classification.

 

4. The quick method for inspectors (2-minute check)

During REACH-CLP controls, inspectors often use a very simple check.

STEP 1

They ask:

“Does the candle contain fragrances or essential oils?”

If the answer is yes, the product is considered a potential chemical mixture for consumers.

STEP 2

They ask for the SDS of the fragrance.

They especially look at section 2.

If they find hazard statements such as:

• H317

• H315

• H411

• H412

they immediately understand that the fragrance is classified.

 

STEP 3

They ask for the percentage used.

If the fragrance is typically used at 5-10%, from experience they know that many candles turn out to be classified.

 

STEP 4

The crucial question comes: “Can you show me the CLP classification of the finished candle?”

If the manufacturer does not have documented classification, a formal verification of the mixture may be requested.

 

Beware of a widespread error

Many manufacturers think it's enough to say:

• “I use little perfume”

• “the fragrance is IFRA compliant”

• “the supplier says it's safe”

But IFRA does not replace CLP.

IFRA establishes limits for fragrance use, while CLP establishes how to classify and label the final mixture.

They are two different systems.

 

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Conclusion

To know for sure if a scented candle requires a UFI code, it is necessary to check if the final mixture is classified according to the CLP regulation.

This requires:

• SDS analysis

• concentration calculation

• verification of CLP thresholds

• eventual classification of the mixture

If this evaluation is not carried out, legal responsibility still rests with the manufacturer.