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The package

A closure is not a package

Updated

On this page7
This is the page the property exists for. The regulation tests a package, not a cap, and the difference is the whole thing.

What gets tested

A specific closure on a specific container, as a system. The thread engagement, the wall stiffness, the finish tolerance and the way the two parts interact all affect whether a child can defeat it, and all of them change when either half changes.

Which means parts are not interchangeable

The same CR closure on a different bottle is a different package and is untested. A stiffer or softer container wall, a slightly different neck, or a different liner can move the result in either direction, and nobody can tell by looking.

What we actually sell

Components. The catalog holds 71 child-resistant closures across ten neck finishes, and they can form part of a compliant package once that combination has been tested. They are not a compliant package on their own and we do not describe them as one.

And an honest note about matching

Across the rest of this library, container pages list closures verified against the neck. Those 71 are not in that verified set, so what we can say here is that the neck notation matches, which is a weaker claim. For anything that matters, confirm the fit physically before committing.

Why the distinction is worth laboring

Because the failure is invisible and the consequence is a child opening a bottle. Somebody who believes they have a compliant package because they bought a CR cap has a false sense of a real protection, which is worse than knowing they have none.

If compliance is required, buy the tested combination

From a supplier who has had that package tested and will say so, or have the testing done. That is the route, and there is not a shortcut through parts selection.

References

16 CFR 1700.15, Poison prevention packaging standards: child-resistant effectiveness of not less than 85 percent without a demonstration, and senior adult use effectiveness of not less than 90 percent. Special packaging must continue to function for the number of openings and closings customary for its size and contents. law.cornell.edu
16 CFR 1700.20, the test protocol. Children aged 42 to 51 months in three bands; panels of 50 rising to 200. Senior adults: 100 participants, 25 percent aged 50-54, 25 percent 55-59, 50 percent 60-70, 70 percent female, with a five minute and then a one minute period, and the package must be opened and properly resecured. law.cornell.edu
Written from the Poison Prevention Packaging Act regulations, not from a test laboratory. Child-resistant packaging is certified by testing a specific package as a system, and nothing here certifies anything. If you need a compliant package, the testing is the route and a matching closure is not a substitute for it.