Short answer
In the EU, finished cosmetic products are outside the classification and labeling rules of the CLP Regulation, but a fragrance oil sold as such — to candle makers, to diffuser and DIY customers, or to another business — is a chemical mixture, so CLP generally applies to it: it must be classified for its hazards and, if hazardous, labeled with pictograms, signal words and hazard statements, and supplied with a safety data sheet to professional users. Separately, the REACH Regulation requires substances manufactured in or imported into the EU in quantities of one tonne or more per year per legal entity to be registered. A small brand buying from EU suppliers is usually a downstream user under REACH; an importer of oils from outside the EU may have registration duties.
Two regulations, two questions
| CLP — Regulation (EC) No 1272/2008 | REACH — Regulation (EC) No 1907/2006 | |
|---|---|---|
| Question | Is this substance or mixture hazardous, and how is that communicated? | Has this substance been registered, and is it used safely? |
| Applies to | Substances and mixtures placed on the market — not cosmetics in the finished state for the final user | Substances on their own or in mixtures, manufactured or imported at one tonne or more per year per legal entity (registration); plus duties along the supply chain |
| Main outputs | Classification, hazard labels, packaging requirements | Registration dossiers, safety data sheets, use conditions |
Which of your products are affected
- A finished perfume sold to consumers is a cosmetic in its finished state: the Cosmetics Regulation governs its labeling, not CLP. See selling perfume in the EU.
- A fragrance oil sold for candles, soap-making, diffusers or DIY perfume is not a finished cosmetic. It is a mixture placed on the market, so it must be classified and, if hazardous, labeled under CLP. Many fragrance oils are classified for skin sensitization, irritation, aquatic toxicity or flammability.
- A fragrance concentrate supplied to another business to make cosmetics is also a mixture; it needs a safety data sheet and CLP-compliant labeling for that supply.
The boundary between a finished cosmetic and an ingredient matters, and the edge cases (bulk supplies, kits) are exactly where to take specialist advice.
What CLP asks of a fragrance oil seller
- Classify the mixture from the hazards of its components, using the regulation's rules. This needs the composition and each component's classification.
- Label it: product identifier, supplier details, pictograms, signal word, hazard and precautionary statements, in the languages of the member state.
- Package it appropriately; some hazard classes need child-resistant fastenings or tactile warnings for consumer sales.
- Provide a safety data sheet to professional and industrial customers.
- Notify poison centers, where the mixture is classified for certain hazards, and print the unique formula identifier (UFI) on the label.
Your raw materials' safety data sheets are the starting point; see fragrance material SDS and specifications. Classification software and consultants exist because the rules for mixtures are detailed.
REACH for a small fragrance business
- Buying from EU suppliers: you are usually a downstream user. Your duties are mainly to use substances within the conditions in the safety data sheets you receive and to pass information along the chain.
- Importing materials or oils from outside the EU: the importer is responsible for registering each substance imported at one tonne or more per year, on its own or in mixtures, unless an "only representative" of the non-EU supplier has registered it. Quantities are counted per legal entity, per substance, per year.
- Mixtures themselves are not registered; their component substances are.
Great Britain operates its own versions of both regimes (UK REACH and GB CLP), with separate duties for GB businesses.
Records you will need
- The full composition of every fragrance oil you sell, and each component's classification.
- Your classification of the mixture, with the reasoning.
- Label versions, safety data sheets and poison center notifications, by product and version.
- Import quantities per substance per year, if you import from outside the EU.
Composition records are the foundation; see perfume raw material documentation. How chemical law sits alongside cosmetics law across markets is summarized in perfume regulations by market, and the US workplace equivalent for safety data sheets in the SDS article.
Sources
- EUR-Lex — Regulation (EC) No 1272/2008 (CLP), including the exclusion of cosmetic products in the finished state in Article 1(5), checked October 9, 2026 (link format).
- EUR-Lex — Regulation (EC) No 1907/2006 (REACH), checked October 9, 2026 (link format).
Frequently asked questions
Do I need CLP labels on perfume I sell to consumers?
Not for a finished cosmetic intended for the end user; it is labeled under the Cosmetics Regulation. CLP applies to fragrance oils and concentrates sold as such.
I sell diffuser oils. Which rules apply?
Diffuser and room fragrance products are not cosmetics, so chemical rules such as CLP apply to them, along with general product safety rules. Take advice on classification and labeling.
Written and reviewed by the RUŌOD Lab team. This article is general education about perfume formulation and record-keeping; it is not legal, regulatory or safety advice, and the examples are illustrations, not validated commercial formulas. How we write and check these guides.