This article was updated on 30.12.2025. This article has been written in accordance with French and European standards, while occasionally addressing certain aspects specific to other countries. Local adjustments may therefore be required depending on the jurisdiction.
Since 2021, a new labelling element has been required on the labels of certain products. This is the Unique Formula Identifier (UFI), a 16-character code. It must appear on the label of all products classified as hazardous to health or physically dangerous in the European Economic Area (EEA). It enables the composition of a mixture to be identified immediately in the event of a call to the poison control centre. The UFI must be visible, legible and affixed to all products with a hazard classification.
The good news is that not all products on sale will necessarily have to be registered.
What are the regulations on candle labels?
Decree no. 2014-128 of 14 February 2014 on toxicovigilance defines notifiable products according to their classification. Manufacturers are required by law to declare certain products to an approved body according to this classification.
In other words, anyone responsible for placing a product on the market is encouraged to make the declaration, so that the INRS and CAPTVs have all the information they need to assess the risk of exposure to a product and to provide medical care in the event of poisoning.
In this particular case, the information is recorded using a UFI number, or Unique Formulation Identifier, a 16-character code that must be affixed to the labels of products classified as dangerous, and which will make it easy to identify a mixture in the event of a call to the poison control centre. Watch this animation (with subtitles enabled) to find out more.
What should be declared? And when?
As we saw in a previous article on CLP labelling, the sale of candles, fluxes and derivatives is regulated. The classification of your finished product must be taken into account, and although the list of hazard categories to be declared has grown steadily over the years, many of your finished products will not need to be registered in the end.
For example, a fragrance-free candle will not need to be registered as it does not contain any substances classified as hazardous. For all fragrance products, whether candles, fluxes, diffusers, etc., those classified in certain categories will have to be declared.
This will be compulsory from 1 January 2021 for new products, and for existing products if they have not already been declared on Synapse.
As soon as a change is made to the formulation, a new UFI and an updated label will be required, particularly in the following cases:
- addition, removal or replacement of an ingredient ;
- variation in percentages exceeding tolerated thresholds;
- modification of the UFI of a mixture used in your own mixture.
Can the same UFI be used for a product in several sizes?
It is possible to use the same UFI for a product offered in several sizes, but only if certain conditions are met. The formulation must be strictly identical and belong to the same creation category. For example, a candle available in 100 ml, 250 ml or 500 ml may retain the same UFI if the composition does not change.
On the other hand, the same UFI cannot cover several product types. A candle and a fondant, even if they have the same formulation, will each require their own UFI number. When a poison control centre checks a UFI on a label, it has to access a file corresponding to one and only one type of product.
So what categories need to be declared?
On the whole, your finished products are rarely classified as very dangerous. You will therefore only be concerned if your product is classified as hazardous to health, i.e. all H statements beginning with 3, or if it is classified as presenting a physical hazard, i.e. all H statements beginning with 2, except : H200, H201, H202, H203, H204, H205, H280, H281.
Please note that EUH208, "contains... May produce an allergic reaction", is not a classification but information. There is therefore no obligation to declare it.
OK, but how do I go about it? How much will it cost me?
The good news is that submitting your UFI declarations is free of charge for France on ECHA's European platform (NCP). For other countries, please read the article to the end.
Here are the essential steps for declaring your product:
1. Create a company account on the ECHA portal (PCN platform)
2. Fill in the information required to generate your UFI:
- your company's VAT number
- internal formulation number (unique code you assign to your mixture)
3. Generate the UFI using the official tool
4. Gather the product's technical information:
- composition of the mixture (ingredients + percentages)
- CLP classification (e.g. irritant, flammable, etc.)
- trade name and manufacturer's name
5. Submit the PCN declaration via the ECHA portal.
6. Affix the UFI code to the label and add it to the SDS.
Once the submission has been validated, your product is registered with the European poison centres. Useful explanatory video here.
What are the differences between countries?
In the majority of European countries, the UFI declaration generates no costs. However, some countries apply their own conditions. It is therefore essential to find out about the regulations specific to your country before taking any steps.
- European Union: declaration via the ECHA platform is free of charge in most countries.
- Belgium: fee of €200 for each notification and €35 for each change or addition. Source : Belgium.be
- Italy: annual fee of €50 per notifier, by bank transfer. Source: Preparati Pericolosi
- Ireland: €650 annual fee or €200 for a maximum of 10 products. Source: Poisons.ie
- Hungary: €53 per initial notification. 40 when the submission is a new notification following a major change in composition.
- United Kingdom: no EU UFI, specific GB CLP system.
- Switzerland: UFI obligation from 01/01/2026, with tolerance for products already on the market before this date (extension to plant protection products planned for 2027).
If you can't find the information you need, we advise you to contact the poison control centre in your country.
Manufacturing and selling candles with simplified CLP labelling: what options are available?
Depending on their composition and fragrance content, some candles can benefit from simplified CLP labelling, while still being fully compliant. This does not mean there is no CLP label, but rather simplified labelling, when the concentration of hazardous substances does not trigger any classification requiring H statements. Terre de Bougies offers several solutions for craftsmen who want to secure their production while reducing the regulatory burden.
It is important to remember that, even when no CLP classification is required, the candle must still carry the mandatory information: product name, contact details of the person responsible for placing the product on the market, weight or volume, as well as any specific information such asEUH208 when a declared allergen is present.
Making candles without a UFI: when is this possible?
In some cases, the UFI declaration is not necessary. In response to this situation, Terre de Bougies offers a selection of over 300 fragrances that can be used up to 7% or 10% without a UFI requirement, as long as your formulation does not reach a threshold requiring a CLP classification with hazard statements.
The collection comprises two ranges:
- fragrances that can be used without UFI up to 7
- fragrances that can be used without UFI up to 10%.
These fragrances, made from a balance of natural and synthetic ingredients that are vegan and not tested on animals, can be used to create candles that comply with the recommended conditions of use. As long as no H classification is triggered, UFI is not required. CLP labelling then remains simplified, limited to the elements required by the regulation (name, coordinates, weight, and EUH208 if applicable).
Reduce CLP labelling as much as possible and avoid UFI with the Boost range
For even lighter CLP labelling, the 1% Boost range is an ideal solution. At this concentration, the fragrances do not trigger CLP classification or UFI requirements, making it much easier to market your candles.
This does not mean that no label is required, but that the label is limited to general mandatory information: product name, manufacturer's contact details, weight and, where applicable, the EUH208 warning if an allergen is present in the formula. The range consists of 10 fragrances:
The safety data sheet (SDS) may sometimes mention precautionary advice such as P101 (if a doctor is consulted, keep the container or label available) or P103 (read carefully and follow all instructions), but their presence is optional. However, it is strongly recommended to include precautionary statement P102 (keep out of reach of children) when applicable, even if it is optional.
Question time
- Where and how should I place my UFI code?
Your code must be visible, legible and indelible, preceded by the word UFI. No specific location is prescribed, but it is usual to place it near CLP-related elements such as pictograms and H/P statements, or near the barcode to make it easier to identify. If the packaging is too small or irregularly shaped, the UFI can be provided on fold-out labels, hang tags or on the outer packaging, always with the other mandatory labelling elements. - Does the UFI allocated to a fragrance in MiM (Mixture in Mixture) mode automatically cover the formulation?
When a perfumer supplies a UFI for his mixture, the candle manufacturer can use it in his own PCN declaration as part of the Mixture in Mixture principle. However, this UFI is specific to each company, with its identity directly linked to it, and must never appear on the label of the finished product. The candle marketed must have its own identifier, generated by the manufacturer on the basis of its overall composition. - Is it necessary to create a new UFI if the fragrance is modified or if additives are added?
Each UFI corresponds to a precise formulation. A new identifier must be established before the product is placed on the market as soon as there is a change in composition, with rare exceptions such as the addition of a colouring agent that does not affect the classification. Any change to the fragrance or addition of an additional classified component should therefore appear on the SDS. For example, a UV stabiliser constitutes a change to the final mixture and therefore requires a new UFI. - Does the same fragrance dosed differently in two ranges of candles require two UFIs?
Yes. A candle scented at 10% and the same fragrance used at 12% result in two distinct mixtures, since the percentages of ingredients differ. As these compositions may lead to different CLP classifications, each must be the subject of its own PCN declaration and have its own dedicated UFI.
We can help you go further
We are informed and specialised in the legal obligations, and our team is at your disposal to help you with these procedures. We offer a 1.5-hour training course to help you complete your UFI declarations yourself. If you don't have the time, we also have a service that can make your declaration to the poison control centre for you.
You can also find an article dealing with the complex regulations concerning fluxes that resemble food.
Conclusion
The UFI is part of a strategy to ensure safety and responsiveness in the event of exposure, by making it easier for poison control centres to identify a mixture immediately. In practice, the challenge is to determine whether your finished product is actually classified, to maintain a stable formulation and to update your label as soon as there is a change in composition. With the right methods, and by choosing solutions tailored to your objectives, you can remain compliant while keeping your labelling as simple as possible. To find out more, we invite you to consult our guide to AFNOR labelling, an essential step that we strongly recommend you take.
Sources :
