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All Containers›Shop by use case›Aromatherapy›The substance›The spray exemptionShop all aromatherapy →
The substance

The spray exemption

By Dwight Davis, Founder

On this page13
Other than those packaged in pressurized spray containers.

The exemption is about the package

Not about the concentration, the use or the labeling. A liquid preparation over the threshold in a pressurized spray container is outside the requirement.

And the only one of its kind in this library. Elsewhere the container is constrained by a rule; here a container choice removes one.

The logic is about access

A pressurized spray container is hard for a child to get the contents out of in quantity, which is the same objective the special packaging requirement serves by a different means.

So the two routes are alternatives, not a hierarchy

Special packaging under 1700.15, or a pressurized spray container. Either satisfies the paragraph as written.

We stock neither

Zero child-resistant closures on this shelf out of 358, and zero aerosol or pressurized containers in the catalog.

The Commission found compliant packaging technically feasible and practicable. It exists; we do not carry it.

A spray closure is not a pressurized container

And this shelf has neither in any case. A finger pump sprayer and an aerosol are different articles, and the exemption names the pressurized one.

Essential oils are rarely sold as aerosols anyway

The format is a glass bottle with a dropper or an orifice reducer, which is what this shelf is. So the exemption is unlikely to be the route a maker wanted.

Which leaves the special packaging route

And that means a child-resistant closure that meets the effectiveness standards while in actual contact with the oil. That phrase has its own section.

And the two routes have different consequences downstream

Special packaging brings the non-reuse sentence and the in-actual-contact requirement with it. A pressurized spray container brings neither of those and brings a pressure vessel instead.

So the choice is not only about availability

It changes what else applies, which is worth weighing before treating one route as simply easier than the other.

Buy it from somebody who stocks it

Which is the honest end of this. For an oil over the threshold, the closure is the product and we do not have it.

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.
16 CFR 1700.15(a): "The special packaging must continue to function with the effectiveness specifications set forth in paragraph (b) of this section when in actual contact with the substance contained therein." The section also requires the packaging to remain effective for the number of openings and closings customary for its size and contents. Paragraph (c): "Special packaging for substances subject to the provisions of this paragraph shall not be reused." The effectiveness figures in paragraph (b) are described rather than quoted here: not less than 85 percent without a demonstration of the proper means of opening and not less than 80 percent after one, with a senior adult use effectiveness of not less than 90 percent for most products. The test protocols in 16 CFR 1700.20 are set out in the pet and veterinary property. law.cornell.edu
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.