In an ever-changing and evolving home fragrance industry, NI Candle Supplies stands firm in its commitment to keeping you, our valued clientele, informed. We are currently facing a crucial industry-wide change involving the reclassification of our Augeo diffuser base. It’s an alteration that may raise many questions, which we aim to address in this comprehensive guide.
If you’re short on time, feel free to skim these bullet points to get yourself up to speed.
- The Augeo diffuser base, a key component in handmade reed diffusers, has been reclassified as "H361d - suspected of damaging fertility or the unborn child". The new classification pertains to the chemical substance and the base it is made with, that being 2,2-dimethyl-1,3-dioxolan-4-ylmethanol; CAS # 100-79-8. It does not alter the brand names, but for ease of understanding, we will refer to the base as Augeo in this article.
- This reclassification does not affect the formulation, effectiveness, or sustainability of Augeo. The substance can continue to be used in diffusers, air fresheners, and room sprays. However, the CLP labelling requirements for these products have changed as a result of this classification, which we will expand on in this article.
- The manufacturers of the chemical that Augeo is made from have proactively self-designated this new classification based on the most recent test outcomes. As this outcome was unexpected, additional testing will take place later this year to confirm or refute the identified adverse effects. In the meantime, we have accepted this new classification, and are taking proactive steps now, rather than waiting for the results.
- We will operate on a changeover system for the relabelling of our Augeo stock. This means that the current stock of the Augeo reed diffuser base available on our website will still be labelled as per the old classification. Please see our FAQ section for more information on the timescales for relabelling below.
- We are currently reviewing our relationship with Augeo during this period of uncertainty. Should we continue to supply this product, new stock will be labelled as per the updated classification; we will provide concise and clear communication of our decision once it has been made.
- For our makers who reside or sell within the EU, it is important to note given the severity of the change in classification. All mixtures using the Augeo Reed Diffuser base will require a new PCN Submission to ECHA including a new UFI number.
- We highly value your feedback and would love to hear whether you plan to continue using Augeo for your reed diffusers despite the reclassification. We are currently testing alternative bases and your input will be crucial in guiding our decisions.
What It’s All About
The reclassification of the Augeo base doesn't affect its performance or its inherent properties. Its efficiency, sustainability, and efficacy remain untouched. The change lies in how we categorise, label, and handle the product in line with a new hazard that has been triggered. It occurred due to the volume of Augeo being manufactured, leading to an extended EU REACH registration testing process.
More specifically, as of July 2023, the substance has undergone a reclassification and is now labelled as "H361d - suspected of damaging fertility or the unborn child". This classification relates to the chemical compounds themselves, irrespective of the brand names they are sold under. In light of this, you may be feeling concerned about how using this base will impact you as a manufacturer.
While there is good reason to be concerned, we want to reiterate that you can continue to use the Augeo Reed Diffuser Base for its intended usage. However, you will need to start using the new classification for any products you make using this base going forward.
It’s also worth noting that the producers of Augeo self-designated this new classification; a proactive move based on the most recent test outcomes. Scientists are rolling out further tests later this year that aim to confirm or refute the adverse effects revealed. They are undertaking this measure because the adverse effects were completely unexpected given that they hadn’t occurred during previous testing.
Will you continue to stock Augeo products under the old classification?
As we navigate these changes, we understand that one of your foremost concerns would be about the impact on our current stock of Augeo. We want to reassure you that products already poured will still fall under the old classification. Should we continue to sell Augeo, the changes will apply to new stock, estimated to be bottled approximately six weeks from now. This grace period should allow us to make a smooth transition without causing any significant disruption to our operations or, more importantly, your business.
Which documents are affected by the change?
We will continue to sell existing Augeo products with previous CLP labelling until our current stocks are depleted, however, the safety data sheets (SDS) have already been updated to reflect the new classification and can be found here. Vendors can continue using the Augeo base while adhering to new labelling requirements or explore alternative bases temporarily or permanently. We remain vigilant, actively monitoring the situation, and will continue to provide updates throughout this change.
Additionally, we're developing new CLP labels for all of our fragrances that are suitable for reed diffuser use and will make these available as soon as possible. Since the changes require updates to the Unique Formula Identifiers (UFIs) - an essential part of the product identification process and an integral part of compliance with the European Chemicals Agency (ECHA) - our makers who reside or sell into the EU, will need to make a new PCN Submission to ECHA including a new UFI number. This is required for each finished product that you make using Augeo.
How does the reclassification affect the CLP label?
The two biggest changes to the CLP label can be seen in the example highlighted below using our Library Fragrance Oil. They are the exploding chest pictogram and the additional hazard statement ‘Suspected of damaging fertility or the unborn child (exposure route)’.
There are also two other additional hazard statements: ‘Do not handle until all safety precautions have been read and understood’ and ‘If exposed or concerned, get medical advice or attention’. It is worth noting the example shown is based on oil that only triggered H317 (may cause an allergic skin reaction) and H319 (causes serious eye irritation) originally with H319 being triggered by the Augeo base.
Should the fragrance oil being used trigger additional hazards, the amount of information required on the CLP label will increase dependent on the hazard statements triggered. In cases where a fragrance does not trigger any hazards when used in a diffuser, H319 and H361 will still be present, meaning the hazard statements in yellow will always be present on diffusers made with Augeo moving forward.
What effect will this have on customers purchasing our products?
The difficulty with the way the label is presented to end users (your customers), is that the information shown does not elaborate on how the product may cause fertility issues or issues to an unborn child and, unless makers are present to explain that the product when used as intended is considered suitable, it is likely buyers will be put off by the warning and not purchase the product.
As makers ourselves, we also have concerns about how an end user would be able to read and understand all the safety precautions when they do not have access to the SDS. Should you choose to continue to offer this product to your customers, we would suggest it is vital to provide clear and accurate communication on these changes.
Given the change in classification is self-appointed, can I just ignore it?
Following discussions with an Industry Expert, our advice is that although technically you can decide whether or not to accept a self-classification, you’d have to have empirical evidence (i.e. your own test results) to show that it doesn’t trigger the new hazard. This isn’t something that actors further down the supply chain (i.e. stockiest and reed diffuser manufacturers) are actually able to undertake, so, unfortunately, we as distributors and you as a maker have no option but to accept the new classification.
To ensure compliance and a smooth transition, the advice we have received and are passing on to you is that vendors can continue using existing CLP labels for their current stock. However, they must ensure the labels are changed within a 6-month time frame or whenever new stock is being made by yourself (regardless of whether the Augeo you have carries the old or new CLP label).
Bear in mind that this is advice only and it is important to seek clarification from your local authorities (Trading Standards, HSE, ECHA, etc). Once you deplete your stock of existing products that contain Augeo and begin creating new batches, you’ll need to update the CLP labels / UFI information (number and PCN).
Be aware of the requirement for tactile warning labels for products classified as H361d and sold to the public—these labels must comply with EN ISO standard 11683 (further information can be found in the EU CLP Regulations, page 19). You might also want to use this as an opportunity to test different bases to replace the Augeo one, either temporarily or permanently.
Your Input Matters
At NI Candle Supplies, we believe in the power of collaboration and community. With this in mind, your feedback is paramount to us. We understand that this change may impact your decisions about the products you choose to use in your creations, so we want to hear from you: Are you likely to continue using Augeo for your reed diffusers despite the change? Or would you prefer us to explore a different base that doesn't trigger such a warning? Please get in touch to tell us what you think or feel free to leave a comment below.
Your input will help us shape the future direction of our products. We're actively testing alternative bases and will be releasing a post covering our findings on the different alternative bases available once testing is complete. However, your preferences will significantly influence our decision-making process. So, if you are already using a different diffuser base and would like us to consider this as part of our research, please reach out to us with your knowledge and experience.
Let's Wrap Up
The primary goal of this message to our customers is that we don't shy away from these changes; instead, we offer transparency, safety and commitment to compliance at every step of the way. We hope this guide has provided you with a better understanding of the reclassification of the Augeo diffuser base and its implications. As always, we remain committed to supporting you through this transition and beyond. We encourage you to contact us with any questions or concerns you may have.
As the industry evolves, so do we, and together, we'll continue to create, inspire and illuminate.
*This blog post provides a comprehensive overview of the reclassification of 2,2-dimethyl-1,3-dioxolan-4-ylmethanol; CAS # 100-79-8, reflecting the latest information as of July 2023. The content is based on the most recent understanding of the situation and information provided by manufacturers. This information is offered in good faith and has no legal recourse, we strongly urge makers to seek their own guidance from the relevant local authorities. NI Candle Supplies remains committed to ensuring the safety and compliance of its products and will continue to provide updates as and when new information becomes available.