Getting started

From formula to product

Updated October 2026

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One: establish which rule you are under Two: work out the percentages by weight Three: choose the closure the rule allows Four: write the label from the rule, not from a template Five: test the label on the filled container And keep a safety data sheet behind all of it Record the five answers together References

Four decisions, and for brake fluid the closure decision is made for you.

One: establish which rule you are under

Brake fluid or hydraulic system mineral oil puts you under 49 CFR 571.116. Anything else, go to your formula sheet and test it against the percentage thresholds in 16 CFR 1700.14 and the labeling triggers in 16 CFR 1500.14.

Two: work out the percentages by weight

Ethylene glycol, methanol and hydrocarbons are all expressed as percentages by weight, and hydrocarbons are summed across components. A formula recorded in volumes has to be converted before any of these tests can be run.

Three: choose the closure the rule allows

For brake fluid, resealable with an impervious inner seal and a tamper-proof feature destroyed on opening. For a product over a child-resistance threshold, special packaging tested to the effectiveness specifications. Both are closure decisions with a rule behind them.

Four: write the label from the rule, not from a template

Brake fluid has seven required items and four verbatim warnings. A glycol coolant has a specified signal word and statement. These are not phrasings to improve, and improving them is the most common way a compliant product becomes a non-compliant one.

Five: test the label on the filled container

S6.14 is a real procedure you can run: slit the label, immerse the container in its own fluid for 15 minutes, wipe it, and read it from 305 mm. Any label and adhesive combination either passes that or does not.

And keep a safety data sheet behind all of it

Hazard communication applies to the shipped container of a hazardous chemical independently of everything above, so the data sheet and the workplace labeling are their own obligation rather than a by-product of the consumer label.

Record the five answers together

Rule, percentages, closure, label text, test result. Change the formula or the supplier and each one needs rechecking, and a written record is what makes that an hour rather than a guess.

References

49 CFR 571.116 S5.2.2, on certification, marking and labeling: seven required items on the container or a permanently affixed label, never on a removable part such as a lid, including the DOT grade, the minimum wet boiling point in Fahrenheit, a packaged-lot serial number and four verbatim safety warnings. S5.2.2.4 moves the labeling to an outer carton where the container is not normally visible. law.cornell.edu

16 CFR 1700.14, Substances requiring special packaging. Paragraph (a)(8) covers methanol at 4 percent or more by weight; (a)(11) ethylene glycol at 10 percent or more; (a)(31) nonemulsion liquid household chemical products at 10 percent or more hydrocarbons by weight under 100 SUS at 100 F. law.cornell.edu

29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. law.cornell.edu

Written from federal regulation and from measured catalog data, not from a blending bench. We sell containers and closures; whether a particular closure satisfies a particular clause is a question about that closure and its supplier’s testing, and nothing here certifies a package as compliant. Anything on these pages is a starting point.