Aerosols

Aerosols have a specific set of rules for classification, and also additional requirements for labelling.

The definition of aerosols in CLP is “aerosol dispensers are any non-refillable receptacles made of metal, glass or plastics and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as a foam, paste or powder or in a liquid state or in a gaseous state“.

Substances never used as aerosol contents

Substances and mixtures classified as:

• pyrophoric,
• self-heating
• water-reactive substances and mixtures

are never used as aerosol contents.

Restriction on substances used in aerosols

Aerosols are subject to several Restrictions, which means that the following substances cannot be used in aerosol form:

• Chloroethene (vinyl chloride) cannot be used as an aerosol propellant
• Any substance classified as flammable gases category 1 or 2, flammable liquids categories 1, 2 or 3, flammable solids category 1 or 2, substances and mixtures which, in contact with water, emit flammable gases, category 1, 2 or 3, pyrophoric liquids category 1 or pyrophoric solids category 1. cannot be used in aerosols for decorative purposes – shall not be used, as substance or as mixtures in aerosol dispensers where these aerosol dispensers are intended for supply to the general public for entertainment and decorative purposes (see restriction for list)
• 2-(2-butoxyethoxy)ethanol (DEGBE) – Shall not be placed on the market for supply to the general public, as a constituent of spray paints or spray cleaners in aerosol dispensers in concentrations equal to or greater than 3 % by weight.

For more details, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/restricted-chemicals/ .

Classification of aerosols

Any product in an aerosol is classified as either:

• an extremely flammable or flammable aerosol, attracts H222 and H229 or H223 and H229 respectively
• a non-flammable aerosol, attracts H229 only

This means that aerosol products are not classified as gas under pressure, flammable liquids, flammable gases or flammable solids.

Classification for flammable hazards of aerosols should include the mass of the propellant.

Classification for other hazards should exclude the weight of the propellant, unless the propellant holds that particular classification.

Paragraph 1.1.3.7. of CLP states:  “Aerosols – In the case of the classification of mixtures covered by sections 3.1, 3.2, 3.3, 3.4, 3.8 and 3.9, an aerosol form of a mixture shall be classified in the same hazard category as the non-aerosolised form of the mixture, provided that the added propellant does not affect the hazardous properties of the mixture upon spraying and scientific evidence is available demonstrating that the aerosolised form is not more hazardous than the nonaerosolised form.”

This means that, when you calculate these hazards, should exclude the mass of the propellant:

• Acute toxicity,
• Skin corrosion/ irritation,
• serious eye damage/ eye irritation,
• respiratory or skin sensitisation,
• STOT SE
• STOT RE

It is important to note on your aerosol classification whether you have excluded the mass of propellant or not.

The logic behind classifying on the basis of two different weights is quite clear: for flammable hazards, the propellant and the non-propellant hazards may have flammability, so both need to be included; but for the other hazards, the product will be used once the propellant has dispersed (e.g. deodorant is left on the skin), so the classification should be on the basis that there is no propellant present.

Extra labelling for aerosols

CLP also states that Aerosols are required under CLP to be labelled in accordance with points 2.2 and 2.3 in the Annex to Directive 75/324/EEC.

These requirements are:

Regardless of aerosol classification, any additional operating precautions which alert consumers to the specific dangers of the product; if the aerosol dispenser is accompanied by separate instructions for use, the latter must also reflect such operating precautions.

For more information, see: Special requirements for aerosol labels