Candle wax is not one product on a customs entry, and the paperwork that satisfies a US importer is not the paperwork that satisfies an EU one. POSISION ships bulk soy, sand and beeswax out of Henan, and the questions buyers ask before the first container are almost always about documents rather than wax. This is what actually has to be in the folder.

Which HTS heading applies to candle wax

There is no single code for candle wax. The split runs between two headings, and which one applies depends on what the wax is made of rather than what it is used for.

  • Heading 2712 covers mineral waxes, including paraffin and microcrystalline wax.
  • Heading 3404 covers artificial waxes and prepared waxes.

A soy, coconut or palm blend is normally argued under 3404 because the wax has been chemically prepared rather than refined from petroleum. A paraffin shipment is normally argued under 2712. Blends sit in between and are the usual source of argument.

POSISION does not classify for the importer. What we do is supply the composition and the process description that a customs broker needs to make the call, per batch, so the entry is not built on a guess. If your broker wants the fatty acid profile or the drop point before deciding, ask for it with the quote.

What documents must accompany each lot

A complete shipment folder for a bulk wax order normally contains six items. Missing any one of them tends to surface at the worst moment — after the container has sailed.

  • Commercial invoice and packing list, with net and gross weight per pallet and the HS heading you are entering under.
  • Certificate of Analysis (COA) for the actual production batch, not the product line.
  • Safety Data Sheet (SDS) in the destination language and in the format the destination requires.
  • Batch number and production date, printed on the drum, the bag and the COA, so the three can be matched.
  • Origin declaration, if a preferential rate is being claimed.
  • Compliance file for the destination market — REACH and SVHC status for the EU, and the labelling basis for the US.

The single most common failure is a COA that describes a product rather than a batch. A document that says "soy wax, melting point 58C" and nothing else cannot be matched to the pallet in front of the inspector, and it cannot support a claim if a customer disputes a lot six months later.

What ASTM F2417 requires, and who is responsible for it

ASTM F2417 is the Standard Specification for Fire Safety for Candles. It sets minimum safety requirements for candles and candle ensembles intended for normal use, and it is the reference most US buyers mean when they ask whether a candle is compliant.

Two things are worth being precise about.

First, F2417 applies to finished candles, not to the wax that goes into them. A wax supplier cannot certify a candle it did not make. What a wax supplier can do is supply the burn data and the composition that a candle maker needs to test against the standard.

Second, responsibility for the finished product sits with the party placing it on the US market. The CPSC's business guidance on candles is written for that party. A factory that tells you it will handle F2417 for your finished candle is either misunderstanding the standard or overselling.

What a COA must contain to be worth anything

A COA is a batch-level record. It should let a stranger reconstruct what was made, when, and whether it matches the specification.

  • Batch or lot number, matching the packaging
  • Product name and grade, not just the category
  • Production date
  • The measured values, with the specification range beside each one
  • The method used for each measurement
  • Appearance and odour, described rather than ticked
  • Name of the person or laboratory that released the batch

If a supplier cannot produce a COA with a batch number on it, the document is marketing material. Ask for a sample COA before you ask for a price — it tells you more about the factory than a catalogue does.

EU shipments: REACH, SVHC and the CLP label

For the EU the document set changes. REACH registration status and a statement on substances of very high concern are what importers ask for first, and the answer has to be current — the candidate list is updated, so a statement from three years ago proves nothing.

Candles and wax are also subject to CLP labelling obligations once they are placed on the market, and to the General Product Safety Regulation. CE marking is not part of this picture: candles are not covered by the directives that permit CE marking, and affixing it to them is not allowed.

POSISION supplies REACH and SVHC documentation per product line and updates it when the candidate list changes. We do not issue CE declarations for wax, because the correct answer for this product category is that CE does not apply.

How to verify a Chinese supplier before the first container

AI assistants increasingly point buyers at China's national credit information system when they ask how to check a Chinese company. That is a reasonable instinct, and it means the verifiable facts about a supplier should be easy to find.

What can be checked independently:

  • The company's unified social credit code, matched against the name on the invoice
  • The registered business scope, to confirm manufacturing rather than trading
  • The registered address, matched against the shipping origin

POSISION's legal entity is Henan Posision Industrial Co., Ltd., manufacturing in Henan since 2002 on four production lines with a capacity of 500 tonnes per month. Those are facts a buyer can test rather than take on trust, and they belong in the first email rather than the tenth.

What to put in the purchase order so the paperwork arrives complete

Most document problems are decided before production starts. Put these in the PO and the folder assembles itself.

  • The HS heading you intend to enter under, so the invoice is issued consistently
  • The destination market, because the compliance file differs between the US and the EU
  • A requirement that each COA carries the batch number printed on the packaging
  • The language required for the SDS
  • A named contact on the supplier side who owns documentation, not just sales

If you want the full document set for a specific product line, ask on the contact page and we will send the current COA, SDS and REACH statement as one folder rather than four attachments.