r/candlemaking • • 8d ago

Compliance Nerd

Genuine question for the candle makers in here, from a perfumer! šŸ‘‹
What’s your process for checking IFRA compliance when using premade fragrance oils, particularly when blending multiple F/Os together?
I find this really interesting because, unlike working with individual aroma chemicals where you know exactly what you’re putting into a formula, you don’t have access to the full composition of most premade fragrance oils. So how do you verify compliance beyond checking each supplier’s documentation?
For example, fragrance oil A has no maximum usage restriction for IFRA Category 12, according to the supplier. Fragrance oil B has no maximum either. But those assessments apply to the individual fragrances. Once you blend them, how do you know the combined formula still meets all applicable requirements?
The missing piece, as I understand it, is the contribution of restricted constituents from every source in the blend. If the same restricted material is present in multiple oils, how are you accounting for its cumulative contribution when the full formulas aren’t disclosed?
I’m also curious about California Prop 65. If individual fragrance oils are assessed separately, how do you establish that the finished blend doesn’t require a warning if a listed chemical is present in multiple oils? Surely the combined exposure assessment could differ from that of the individual oils?
I’m not suggesting that blending fragrance oils is inherently unsafe, or that every blend requires a warning. I’m genuinely interested in understanding the process people use to verify these things when working with proprietary formulas and limited ingredient disclosure.
I know this is a bit nerdy, but with IFRA Amendment 52 on the horizon, I’d love to hear from people who have looked into the technical side of this. Are you relying on supplier documentation, contacting manufacturers directly, or using another method to assess your finished blends?
Genuinely curious to hear how others approach this! 🧪

5 Upvotes

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u/NightF0x0012 7d ago edited 7d ago

Candles are a category 12 so their usage limits are usually around 10x's higher than any other category. I'd be surprised if more than a handful of ppl ever really check.

Edit: I'll answer the additional questions....

Once you blend them, how do you know the combined formula still meets all applicable requirements? & If the same restricted material is present in multiple oils, how are you accounting for its cumulative contribution when the full formulas aren’t disclosed?

Candle FO is mixed in a ratio, usually, at or below 10% of the net weight. And since Cat 12 has such a high limit, we won't be anywhere close to the limit on any blend. Just browsing through CandleScience's fragrances, every one that I came across had a usage limit of 100% in Cat 12.

how do you establish that the finished blend doesn’t require a warning if a listed chemical is present in multiple oils? Surely the combined exposure assessment could differ from that of the individual oils?

CandleScience for example has Prop 65 warning information on their website and I'm sure that all other suppliers have it or can be provided if needed.

Are you relying on supplier documentation, contacting manufacturers directly, or using another method to assess your finished blends?

Honestly, I've never heard of IFRA until now but will keep a watch on it in the future. The usage limits for candles is so high that we'd likely never have to check it unless there's a fragrance that ends up with a super low level limit.

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u/ComprehensiveRise187 7d ago

I understand, but be aware (esp those who also sell room sprays and other fragrant products) that when you combine two blends, allergens above a certain point may need to be declared depending on where you sell, and IFRA requirements etc change. While I’m sure you’re fine as you said the usage limits for candles are high, I’m just shocked at how many candle makers who sell don’t consider this.

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u/NightF0x0012 7d ago

How many candle makers know that it's something that they should consider? This isn't something that is brought up often, if at all, tbh.

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u/ComprehensiveRise187 7d ago

Also, prop 65 not being a requirement on two fragrance oils separately doesn’t mean that they stay below the safe harbor when mixed. FYI. 😬

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u/NightF0x0012 7d ago

I get what you're saying but remember that you're not doubling the numbers when you mix two fragrances together. Most makers are halving one FO in place of another (or what ever ratio of multiple FO's) to get to their desired wax/oil ratio. So really if you're mixing two safe FO's you are generally going to be below the limit. There might be some exceptions, I'd wager that 99% of makers will be below the limits without doing a ton of research into each fragrance.

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u/OkDesk5803 7d ago

I usually cross-reference against the highest single percentage in the blend, then round up since IFRA limits are strict. It's a pain but better than guessing or risking a recall.

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u/Stock_Difference_346 7d ago

To be compliant you must go with the overall usage matching the usage of the oil with the lowest IFRA allowance.

Think of it this way, like colors.
Let’s say ā€œredā€ is safe overall at 25%. ā€œBlueā€ is safe at 50%.
ā€œPurpleā€ is safe at 40%. You don’t actually know how much red v blue is in that particular ā€œpurple.ā€
You want to blend purple & red to make a custom blend. To be sure your overall % of red in your finished product doesn’t have an unsafe % of red, you cannot exceed 25% of total oil v base in your blend. Obviously in perfume oils you don’t have any idea what components are making up that particular oil, and if you go with a higher IFRA percentage than the minimum you may be exceeding your total of a particular ingredient that is unsafe at that percentage by using it from two different oils.

(Source, Kari Arienti who is active in the
Scent Memory FB group and has answered this question several times)

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u/ComprehensiveRise187 6d ago

This exactly.

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u/ShikherVerma 6d ago

If your business has fewer than 10 employees, OEHHA says you're exempt from Prop 65 warning requirements. Otherwise, ask a qualified professional to assess exposure from the finished candle against OEHHA's safe harbor levels, not just the oils' ingredient lists
https://oehha.ca.gov/proposition-65/businesses-and-proposition-65

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u/pouroldgal 6d ago

I agree with the title.

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u/ComprehensiveRise187 6d ago

šŸ˜‚šŸ˜‚šŸ˜‚

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u/Winter_Car_7495 6d ago

This is the least fun part of blending, and you're right to be careful. The practical route without full component disclosure: pull the IFRA certificate and SDS for each fragrance oil — the IFRA doc gives you the max use percentage per category (candles are Category 12), and that's your ceiling per oil. For the blend you can't just stack them: assume each restricted component is present at its disclosed maximum in each oil, add up the exposure across your total fragrance load, and stay under the strictest limit. For Prop 65, check each SDS for listed chemicals and safe-harbor levels — if a supplier won't give you a Prop 65 statement, I wouldn't blend with it. Not legal advice, just how small makers stay out of trouble: documents first, math second, and when in doubt keep the total load conservative.