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What goes wrong

Assuming the package is compliant

Updated

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The failure with the worst consequences in this property is not mechanical. It is somebody believing they have compliance they never bought.

How it happens

A catalog lists a closure as child resistant, which is a true description of the closure. Somebody buys it, fits it to a bottle, and reasonably concludes the package is child resistant. Nobody lied and the conclusion is wrong.

Why it matters more than an ordinary mistake

Because the belief changes behavior. A household told a package is child resistant stores it less carefully than one told it is not, so a false claim can leave people worse off than no claim at all.

The check

Ask what was tested, as a combination, and whether you can see the documentation naming the parts you are buying. If the answer is about a closure rather than a package, you have a component.

Watch your own copy

If you repackage and sell on, describing your product as being in child-resistant packaging is a claim you are making. The same question applies to you that you would ask your supplier, and the answer has to be as good.

Know whether you are required to use it

The substances that must be in special packaging are listed in the regulations. Whether your product is on that list is a specific question with a specific answer, and it is not inferable from the product category or from what competitors do.

When in doubt, describe the mechanism

Saying a cap is push-and-turn is accurate and useful and claims nothing about certification. It is the honest description available to anybody selling components rather than tested packages.

Write down what you concluded and why

A short note recording that you checked whether the product requires special packaging, what you decided and on what basis, is worth keeping. It is the difference between a considered decision and an assumption nobody can reconstruct later.

References

16 CFR 1700.14, the list of substances required to be in special packaging. law.cornell.edu
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
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.