CANDLE LABELING
Key Laws and Standards
The following information is being provided as a general overview of the key laws, guidelines and
standards relating to the labeling of candles. This information is neither complete nor definitive, and
should not be construed as legal advice. For more complete information, please review the resource
listings provided and/or consult with legal counsel.
U.S. FEDERAL LAWS
Fair Packaging & Labeling Act -– FTC
The primary consumer product labeling law in the United States is the Fair Packaging
and Labeling Act (FPLA). It applies to consumer products; it does not apply to products intended
for institutional or industrial use. The purpose of the FPLA is to provide consumers with
accurate information about the product to facilitate value comparisons and to prevent unfair or
deceptive packaging and labeling of consumer commodities.
The Federal Trade Commission (FTC) administers the FPLA as it relates to household
consumer commodities, which includes most candles. The FPLA requires consumer products to
be labeled for identity, net content, and manufacturer/distributor name & place of business.
Product Identity: This is the product’s common name, such as “candle” or “scented candle.”
Net Content: This is the quantity, size and/or weight measurement of the product. The
measurement must be provided in both imperial (ounces, inches, etc.) and metric units (grams,
centimeters, etc.).
Although the FPLA generally calls for products that are solid or semi-solid to be measured in
terms of dry weight or mass, it also allows alternative measurement units if they’re accepted by
consumers or typically used by industry and allow for value comparison by consumers. Over the
years, candles have typically been labeled for net content as follows:
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Container candles and votives – dry weight (e.g. ounces/grams), although gels are
sometimes measured in fluid ounces/milliliters.
Pillars – diameter and height (e.g., 3 in x 8 in/ 7.6 cm x 20.3 cm)
Tapers – count and height. The FPLA specifically exempts tapers from a diameter
measurement. Thus, an 8” taper can simply be labeled as 8 in. / 20.3cm.
Tealights – count, or count and metric dimensions. For example, 50 tealight candles or
50 tealight candles (38 mm x 19mm).
Manufacturer/Distributor Name & Place of Business: The “place of business” is considered
to include a company’s street address, city, state and zip code, unless the company can be found
in the local phone directory. In that case, only the city, state and zip code are needed (e.g., Acme
Candle, Washington DC 20005). It is acceptable to substitute “distributed by ______” or
“manufactured for ______” Note: Under the amended Tariff Act of 1930, all imported items
must be marked with the country of origin. (19 U.S.C. 1304)
Location of Labeling Information: Both the product identity and the net content must appear
on the product’s Principal Display Panel (PDP). The PDP is defined as “that part of a label that
is most likely to be displayed, presented, shown or examined under normal and customary
conditions of display for retail sale.”
Although the name and location of the manufacturer/distributor must be conspicuous, it
does not need to appear on the principal display panel. The FPLA has a variety of specific
requirements regarding the placement of information on labels, type sizes, etc. and other
requirements. For more information on the FPLA as administered by the FTC, including links to
the statute, go to http://www.ftc.gov/os/statutes/fplajump.shtm
Fair Packaging & Labeling Act -- FDA
The Food and Drug Administration (FDA) administers the FPLA as it relates to food,
drugs, cosmetics and medical devices. Because “lotion” candles are considered cosmetics, their
labeling falls under the purview of the FDA. Generally the FDA labeling requirements for
product identity, net content, and manufacturer/distributor name & location are similar to the
FPLA requirements for household consumer commodities under the FTC (see above).
It is important to note, however, that the FDA’s cosmetic labeling requirements also
necessitate ingredient listing in descending order of predominance, as well as other ingredient
restrictions under the federal Food, Drug & Cosmetics Act. In addition, no cosmetic may be
labeled in a manner that suggests the FDA has approved the product.
FDA ingredient restrictions and labeling requirements are thoroughly discussed in the
FDA’s Cosmetics Labeling Manual. See http://www.cfsan.fda.gov/~dms/cos-lbl.html
Pesticide Labeling (Citronella Candles) -- EPA
Citronella candles (i.e., candles designed to repel insects) are officially pesticides. As
such, they are subject to registration and labeling as minimum risk pesticides under Section 25
(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which is administered
by the Environmental Protection Agency (EPA). By comparison, a candle that contains
citronella as a fragrance but with no intent of repelling insects would be labeled as a household
consumer commodity under the FPLA as administered by the FTC.
General labeling provisions under FIFRA are very similar to the FPLA in terms of
principal display panels, product identity, net content, and manufacturer/distributor name and
location, etc. However, FIFRA labeling requires each active ingredient to be listed by name and
percentage (by weight), and that inert ingredients be listed by name. Although a label may make
claims about the product’s pesticide properties (e.g., repels mosquitoes), it cannot make any
health-related claims, such as fights malaria or malaria-carrying mosquitoes. See
http://www.epa.gov/pesticides/biopesticides/regtools/25b/25b-faq.htm
Note: Individual states are also authorized to regulate pesticides and may have more
restrictive labeling or usage requirements than the EPA, which would impact citronella candles.
Metal-Core Wick Certification -- CPSC
Any shipment of metal-core wicks, or candles with metal-core wicks, must indicate on
the shipping box/container that the product complies with the Consumer Product Safety
Commission’s ban on lead wicks [16 CFR. § 1500.17 (a)(13)] and thus contains less than 0.06%
lead by weight.
In addition, under the Consumer Product Improvement Safety Act of 2008 (CPSIA),
manufacturers/distributors of metal-core wicks and/or candles made with metal-core wicks must
provide certification information indicating the manufacturer’s name, location and date when the
metal-core wick or candle was made; the date when the wire was tested for lead content and by
whom; and contact information for the custodian of the test records. Certification information
may be provided on a website, if so noted on the shipping container or accompanying document,
but does not have to appear on the finished product. For more information, contact the NCA.
California Law (Proposition 65)
Under a Proposition 65 settlement, scented candles with a diameter of 3.5 inches or more
must include a warning on the label that substantially says: “To reduce sooting, you must trim
the wick to ¼ inch each time the candle is to be relit. Avoid using in drafty areas.” The warning
must be in a typeface, size and location “as conspicuous as” other safety warnings on the label.
Other U.S. State Laws
Additional labeling regulations issued by the weights and measures divisions of certain
states may also be applicable to candles. Also, state laws on labeling citronella candles may vary.
Canadian Law
Canadian labeling regulations require that all text appears in both English and French
(except trademarks and the manufacturer name and address) and that both language texts are of
the same type size and prominence. For candles, this would include the statement of product
identity, net content, fire safety warning, and other instructions deemed appropriate. See
http://www.collectionscanada.gc.ca/webarchives/20071114211633/http://www.competitionbureau.gc
.ca/internet/index.cfm?itemid=1248&lg=e#top (scroll down toward bottom of page)
Mexican Law
Mexico requires product labeling in Spanish, although English may be included. The
basic requirements generally parallel those of the FPLA in the U.S. -- product identity; net
contents (in metric units); name & address of manufacturer; country of origin; precautionary or
safety statements, any other instructions, plus the name and address of the importer.
The key labeling laws applicable to candles (provided only in Spanish) are NOM 008SCFI, NOM 030-SCFI and NOM 050-SCFI. See http://www.economia-noms.gob.mx/ (go to
“tipo”, then “definitiva” and search by NOM number). The U.S. Commerce Department can
provide further assistance. See http://www.buyusa.gov/mexico/en/doing_business.html
EU Law
EU labeling regulations for candles require the name of the product, net content,
name/location of manufacturer, country of origin, and any use instructions or warnings (such as
the CEN fire-safety warning label). Labeling must be in the language of the country of
consumption, but additional languages may also be required. The U.S. Commerce Department
can provide further assistance: http://www.buyusa.gov/europeanunion/standards.html
Note: Unless the EU amends its directives, as of January 1, 2010, “metric-only” labeling
will be required for consumer products sold in the EU; imperial measurements may not be added.
LABELING STANDARDS
ASTM F-2058
In the U.S., candles sold to consumers should be labeled for fire-safety according to the
ASTM F 2058 standard. The standard sets forth the wording, typestyle and graphic design
requirements for the label, which includes the warning symbol and three textual cautions:
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Burn within sight
Keep away from things that catch fire
Keep away from children
A pictogram-and-text option is allowed and a variety of label examples, including
Spanish and French versions, are provided in the standard. Candles sold in Canada should carry
the warning in both English and French. In Mexico, the text must at least be in Spanish. Order
the standard at www.astm.org using F2058 as the keyword. The cost is approximately $40.
Artwork for the pictograms can be downloaded without charge at www.candles.org/pictograms.
European Union - EN 15494
Candles sold in the EU should be labeled in accordance with CEN (Comité Européen de
Normalisation) standard for candle product safety labels and warnings. This standard, akin to
ASTM F-2058, requires the triangular warning symbol and four fire-safety messages:
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Never leave a burning candle unattended
Burn candle out of the reach of children and pets
Always leave at least ___ cm between burning candles (distance as determined by mfr.)
Do not burn candles on or near anything that can catch fire.
The warnings can be provided textually OR in the form of pictograms (which are different
from the ASTM pictograms).. There is no size requirement for the text or pictograms other than
they must be “visible and legible on the packaging or product.” If the textual warning is used, it
must be in the language of the country where the candles are marketed, although additional
languages also may be required.
An English-language version can be purchased and downloaded through the British
Standards Institute (see link below). If using this website, the standard’s reference number
should be prefaced with the letters “BS”, i.e., BS EN 15494. The cost is approximately $120.
http://www.bsi-global.com/upload/Standards%20&%20Publications/shop.html?epslanguage=EN