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The substance

One name, one percentage

By Dwight Davis, Founder

On this page11
More than 5 percent by weight. A threshold on a named chemical, not on a product category.

The paragraph

"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)."

It names a chemical, not an oil

Which is why it reaches any liquid preparation over the threshold, whether it is sold as an essential oil, a liniment, a rub or a blend.

By weight, not by volume

Which matters for a dense material in a light carrier, and means the calculation is a formulation one rather than a bottling one.

More than 5 percent

So exactly 5 percent is outside it. A threshold expressed as more than is a different boundary from one expressed as at least.

And it applies to liquid preparations

A solid or a semi-solid preparation is not reached by this paragraph as written, which is a distinction worth noticing on a shelf that includes 10 tins.

The opening of the subsection explains why

The Commission has determined that the hazard to children in the availability of the listed substances, by reason of their packaging, requires special packaging, and that such packaging is technically feasible, practicable and appropriate.

Which is a finding about packaging as much as about chemistry

By reason of their packaging. The hazard identified is the combination of the substance and the container it is available in.

And the feasibility finding is part of the determination

Technically feasible, practicable and appropriate for these substances. The Commission is saying a compliant package can be made, which our catalog does not reflect.

The exemption is a packaging form

Other than those packaged in pressurized spray containers. So the container type can remove the requirement, which is unusual.

And that form does not exist in our catalog

Zero aerosol and zero pressurized containers, checked catalog-wide. So the exemption is not a route from here either.

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.
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.