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Do you need a child-resistant closure?

Updated October 2026

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Work it out in the finished product The thresholds Worked example What to do if you are over References

An arithmetic check against a published list, and the arithmetic is where people get it wrong.

Work it out in the finished product

The thresholds in 16 CFR 1700.14 are stated as percentages by weight in the household substance as sold, not in the raw material.

So the calculation is: raw material concentration x the amount you add, as a percentage of the batch.

Check every product in the range separately, and re-check on every reformulation and on any supplier change where the raw material strength might differ.

The thresholds

Sodium or potassium hydroxide: 2 percent or more by weight in liquid; 10 percent or more in dry forms such as granules, powder and flakes.

Methyl alcohol (methanol): 4 percent or more in liquid, other than in pressurized spray containers.

Sulfuric acid: 10 percent or more.

Turpentine: 10 percent or more in liquid.

Ethylene glycol: 10 percent or more in liquid.

Nonemulsion liquid furniture polish with 10 percent or more mineral seal oil or other petroleum distillates below 100 SUS, other than in pressurized spray containers.

Liquid kindling or illuminating preparations with 10 percent or more petroleum distillates below that viscosity.

The list is longer than this; these are the entries a cleaning products maker meets.

Worked example

A degreaser using sodium hydroxide supplied as a 50 percent solution, added at 5 percent of the batch.

50 percent x 5 percent = 2.5 percent in the finished product.

The threshold is 2 percent. This product requires child-resistant packaging.

Reduce the addition to 3.5 percent and the finished concentration is 1.75 percent, which is under. That is a formulation decision with a packaging consequence, and it should be made deliberately rather than discovered.

What to do if you are over

Specify a closure certified to the standard in 16 CFR 1700.15, tested by the protocol in 1700.20, and keep the supplier's documentation.

Match it to the bottle finish: the package as a whole has to perform, so the closure and the bottle are a tested pair rather than two parts.

And check the cautionary labeling at the same time, because a formula strong enough to cross this threshold almost certainly needs FHSA labeling too.

References

Poison Prevention Packaging Act, 16 CFR 1700.14, Substances requiring special packaging. Thresholds relevant to household cleaners include sodium and/or potassium hydroxide at 2 percent or more in liquid (10 percent dry), methyl alcohol at 4 percent, sulfuric acid at 10 percent, turpentine at 10 percent, and nonemulsion liquid furniture polish with 10 percent or more petroleum distillates below 100 SUS. ecfr.gov

16 CFR 1700.15 and 1700.20, the effectiveness standards for child-resistant packaging and the protocol for testing it against children under five and normal adults. ecfr.gov

Federal Hazardous Substances Act and 16 CFR Part 1500, which require cautionary labeling on household products containing hazardous substances: the signal word, the hazard, precautionary measures, first aid and the instruction to keep out of reach of children. ecfr.gov

Written from the federal regulation and agency guidance named on each page, not from a laboratory or a legal practice. Whether a particular product and a particular label make a cleaner or a pesticide is a determination about your product, and this is not that determination.