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Two doors, both shut

On this page11
Zero child-resistant closures out of 358. And no pressurized container anywhere in the catalog.

The rule names one substance

Liquid preparations containing more than 5 percent by weight of methyl salicylate, other than those packaged in pressurized spray containers, shall be packaged in accordance with the special packaging provisions.

So there are two ways to satisfy it

Special packaging, which means a child-resistant closure meeting the effectiveness standards, or a pressurized spray container.

This shelf has no child-resistant closure

None of the 358 closures indexed to this group is child resistant. 202 are plain continuous thread polypropylene lids and 43 are dropper assemblies.

And the catalog has no pressurized container

Checked catalog-wide: no aerosol and no pressurized spray container of any kind. The exemption is as unavailable as the requirement.

Which makes this a narrow refusal

Not for the whole group. For a liquid preparation over 5 percent methyl salicylate, this catalog cannot supply a compliant package by either route.

5 percent by weight is not a close call for some oils

A single-ingredient wintergreen or sweet birch oil is overwhelmingly methyl salicylate, so the threshold is exceeded by a wide margin rather than approached.

And neither of those appears as a leaf here

The group names roughly thirty oils and wintergreen and sweet birch are not among them. Which does not settle the question, because a blend can contain either.

The oils this group does name are not on the list

Clove, oregano, thyme, eucalyptus, peppermint, tea tree and the rest. That is a statement about the list and not about the oils.

Absence from a list is not a safety finding

Which is the careful half of this property and has its own section. Nothing on these pages says whether any oil is safe or hazardous.

What we do have is a good oil shelf

95 glass containers, 63 of them boston rounds, 43 dropper assemblies, 10 tins and a working roller ball system. For everything outside the threshold that is a real offering.

References

16 CFR 1700.14(a)(3): "Methyl salicylate. Liquid preparations containing more than 5 percent by weight of methyl salicylate, other than those packaged in pressurized spray containers, shall be packaged in accordance with the provisions of Sec. 1700.15 (a), (b), and (c)." The opening of subsection (a) reads: "The Commission has determined that the degree or nature of the hazard to children in the availability of the following substances, by reason of their packaging, is such that special packaging meeting the requirements of Sec. 1700.20(a) is required to protect children from serious personal injury or serious illness resulting from handling, using, or ingesting such substances, and the special packaging herein required is technically feasible, practicable, and appropriate for these substances:" The other substances named in that subsection are not enumerated on these pages. law.cornell.edu
The Davis Pack Supply catalog, measured 19 October 2026. None of the 358 closures indexed to this group is child resistant, and a catalog-wide check finds no aerosol or pressurized spray container of any kind. So neither of the two routes in 16 CFR 1700.14(a)(3) can be taken with anything on this shelf.
The leaves in this group name roughly thirty essential oils, including clove, oregano, thyme, eucalyptus, peppermint and tea tree, and methyl salicylate is not among them. Neither wintergreen nor sweet birch appears as a leaf. Nothing on these pages says whether any of those oils is safe or hazardous: the point is structural, that 16 CFR 1700.14(a) is a list of named substances and a substance not appearing on a list has not thereby been found safe.
Written from 16 CFR 1700.14 and 1700.15 and from the catalog as it stood on 19 October 2026. Nothing on these pages says whether any essential oil is safe or hazardous, and nothing addresses dilution, exposure or use. The paragraph quoted here names methyl salicylate at a 5 percent by weight threshold; the other substances in 16 CFR 1700.14(a) are not enumerated here and absence from a list is not a safety finding. This shelf holds no child-resistant closure and the catalog holds no pressurized spray container, so neither of the two compliant routes in that paragraph is available from it.