What are the Child Resistant Closure Requirements for Essential Oils?
We have a line of home fragrance products. We ship essential oils and fragrance oils to the U.S. and EU, and have three questions regarding child-resistant caps. (A) Is a child-resistant closure needed in U.S. and EU market? (B) Is a diagram on the top of cap required to teach the customer to 1) push down then 2) turn to open? (C) Are there any regulations regarding the technique of diagram expression? For example, can we use a sticker to tell the customer how to open the product?
In the U.S., the Poison Prevention Packaging Act (PPPA) requires child-resistant packaging for certain products. Title 16, Part 1700 of the U.S. Code of Federal Regulations (C.F.R.) defines a child-resistant package and specifies what products require such packaging. (The regulations can be found here.) For example, liquid products containing 4% or more by weight of methyl alcohol require child-resistant packaging.
In the European Union (EU), the Dangerous Substances Directive (67/548/EEC) requires child resistant packages for certain substances. The European Committee for Standardization (CEN) has published standards for child resistant packaging, including EN 862:2001 'Packaging – Child resistant packaging – Requirements and testing procedures for non-reclosable packages for non-pharmaceutical products' and EN 28317 relating to child resistant reclosable packages. More information on these standards can be found on CEN's website.
We recommend that you retain Keller and Heckman or another qualified attorney to determine the requirements that apply to your specific products.