Europe versus US on aerosol can regulation

When looking at an aerosol from the US market and one from Europe you would be hard pressed to notice any significant differences from a simple visual examination. However, the regulations in Europe and in the US are quite different and anyone looking to export from one market to the other should be aware of the facts.

In Europe, the construction of an aerosol can is regulated by the Aerosol Dispensers Directive (ADD).  As a Directive this has then been enacted into law in each member State as an individual regulation. For the UK this is the 2009 Aerosol Dispensers Regulation. For Europe, the regulations require you to carry out deformation and bursts tests on the cans to ensure consumer safety. The pressure the can must resist is determined by the expected pressure of the product inside the aerosol at 50°C.  The table below details the requirements, and also shows the latest change to the ADD which allows you to fill aerosol cans with non-flammable compressed gases up to a pressure of 15 Bar.

EU Maximum Pressure at 50°C Test Pressure (Bar) Minimum Burst Pressure (Bar) EU Can Designation Comments
≤ 6.7 10 12 10 Bar
8 12 14.4 12 Bar
10 15 18 15 Bar
12 18 21.6 18 Bar
13.2 19.8 23.8 20 Bar Non-flammable propellants only
15 22.5 27 22.5 Bar Non-flammable compressed gas propellants  only

You will see that the test pressure is a 50 per cent increase on the pressure of the product inside the can at 50°C and that the aerosol must not burst until the pressure is at least 20 per cent above this.

For the US, the requirements relate to pressure resistance but also make specific requirements with regard to the wall thickness of the container. These are specified by the US Department of Transport (US DoT) and are a legal requirement for the road transport of filled aerosol cans. The US regulations look like this:

USA Maximum Pressure at 54.4°C (130°F) (Bar) Test Pressure Burst Pressure (Bar) USA Can Designation Comments
9.66 (140 psi) n/a 14.49

(210 psi)

Unclassified Body Gauge not stipulated
11.03 (160 psi) n/a 16.55

(240 psi)

DOT 2P Minimum wall thickness 0.18mm (0.007”)
12.41 (180 psi) n/a 18.62

(270 psi)

DOT 2Q Minimum wall thickness 0.2mm (0.008”)

The important difference on pressure resistance between the US and EU is that there is no test pressure. The only requirement is for the can to conform to the burst pressure limits.  These regulations are the same for tinplate and aluminium aerosol cans. For the US, the cans must be labelled with their designation if they meet either the 2P or 2Q standard.

The important thing for exporters between these two markets to recognise is that a can designed to meet US regulations may not meet those for the EU and visa-versa. For example, the EU requirements are based on the internal pressure at 50°C, whereas in the US the reference pressure is 130°F (54.4°C). In Europe, the side wall thickness of aerosol cans, has been downgauged over the years, whilst improvements in materials has allowed the pressure resistance of the can to be maintained.  When looking to use a US can in the European market, the marketer must ensure that the performance of the can, required by the European regulations, has been met.

As you can imagine, there are a number of other regulations on construction, dimensions, testing and inspection for both markets. For any aerosol can manufacturer or filler it is very important to ensure that the products they produce conform to the regulations in the market in which they are to be sold.

When looking to export beyond the US and EU, local regulations should be checked. In general, countries across the globe have based their aerosol regulations around either the European or US models and may accept cans which meet either. However, it is essential for anyone marketing an aerosol not to assume that meeting the regulations in their local or primary market will mean that the product can be sold elsewhere in the world.

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