Safety Data Sheets for Soy Candles – A Legal Obligation Often Overlooked

Soy candles have become increasingly popular as a “natural” and eco-friendly alternative to traditional paraffin candles. However, from the perspective of chemical regulations, natural does not mean exempt. If you manufacture or sell soy candles that contain fragrances, dyes, or other additives, you may be legally required to provide a Safety Data Sheet (SDS).

Soy Candles as Chemical Mixtures

Under the REACH and CLP Regulations, a soy candle with additives is often classified as a chemical mixture, rather than a finished article. Wax, fragrance oils, dyes, fixatives, essential oils – any of these components can trigger classification obligations.

If any ingredient is classified as hazardous under CLP Regulation (EC) No. 1272/2008, the entire product may be subject to:

hazard classification,
CLP-compliant labelling,
and the requirement to prepare an SDS.

Whether or not you are legally obliged to provide an SDS will depend on the classification of individual raw materials, the final formulation, and how and where the product is marketed.

When Is an SDS Mandatory?

SDSs are not mandatory for mixtures intended solely for consumer use. However, the situation changes if:

you employ staff who handle the product (e.g. in packaging or dispatch),
your products are supplied to professional users (e.g. spas, retail chains),
a business customer requests an SDS (which is their right).

In such cases, a Safety Data Sheet must be provided, and failing to do so may result in administrative penalties.

As a result, many soy candle producers choose to prepare SDSs proactively, to keep distribution channels flexible and meet customer expectations in B2B settings.

Legal Basis for SDS Obligations

For substances, an SDS must be provided if the substance:

is classified as hazardous,
is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB),
is listed as a Substance of Very High Concern (SVHC) under Article 59 of REACH.

For mixtures, an SDS is required if the mixture:

is classified as hazardous,
contains substances hazardous to human health or the environment (e.g. carcinogenic, mutagenic, reprotoxic),
contains substances with an EU-established occupational exposure limit (OEL).

If you are unsure whether your candle product requires an SDS – it is advisable to perform a compliance assessment.

What Should an SDS for Soy Candles Include?

A well-prepared SDS for a soy candle classified as hazardous should include, among other things:

hazard identification (e.g. H317 – may cause an allergic skin reaction),
detailed composition with concentration ranges of hazardous substances,
handling precautions and first aid measures,
firefighting instructions (especially important for flammable products),
transport, storage, and disposal information.

📝 For a full list of SDS requirements, check out our guide: [Safety Data Sheets – A Quick Guide]

What About Labelling?

If your soy candle is classified as hazardous, CLP-compliant labelling becomes mandatory. This includes, but is not limited to:

appropriate hazard pictograms,
H- and P-statements,
supplier identification details.

⚠️ Label-SDS consistency is critical – discrepancies are a common reason for non-compliance notices during inspections, including in online sales.

Do Your Soy Candles Require an SDS?

If you manufacture, package or sell soy candles with fragrances, colourants or additives, it’s important to assess their classification and regulatory obligations under REACH and CLP.

This ensures not only legal compliance but also product safety and commercial flexibility across EU markets.

How SDS Create Can Help

At SDS Create, we support soy candle makers, importers and private label brands with:

✅ classification and compliance assessment

✅ preparation and review of Safety Data Sheets

✅ compliant labelling

✅ full regulatory documentation audits

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