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All Containers›Shop by use case›Nail›Tools and directories›The check, before the first fillShop all nail →
Tools and directories

The check, before the first fill

By Dwight Davis, Founder

Updated

On this page9
Five questions, and two of them have to be answered for every size you sell.

One: methacrylic acid, as a percentage

More than 5 percent weight to volume in a single retail package triggers special packaging. Compute it on that basis, not weight for weight, and write the figure down rather than the conclusion.

Two: acetonitrile, as a mass per container

More than 500 mg in a single container. Concentration times fill volume, recomputed for every size, including any size added later. This is the one that gets missed.

Three: is the format the exemption, or the requirement?

A pen-like applicator holding no free liquid, emerging only through the tip under any reasonably foreseeable use, is outside the methacrylic acid requirement. A bottle is inside it. Decide this before tooling.

Four: does the fitment exist on your neck?

For a polish, shop the brush caps directly: 18-400, 18-410, 20-400 or 28-400, read as full finishes rather than diameters. For a treatment, the dropper assemblies on that shelf are already matched per neck.

Five: label it for what it is

A polish, a cuticle oil and a treatment are cosmetics with ingredients in descending order of predominance. A remover at 10 percent or more petroleum distillates carries the specified signal word and two statements.

And test the closure against the solvent, over months

Liner, brush stem, bristles and dropper bulb, with a weighed control sample. Every compatibility failure in this category is slow and none of them is visible on the filling day.

File the answers per size

Both threshold calculations, the format decision, the fitment and its finish, and the label version, for each size in the range. A size extension reopens at least the acetonitrile arithmetic, and often more.

The order matters because the format is a lever

Compute the thresholds first, because knowing you are over one of them is what makes a pen applicator or a smaller fill worth considering. Choosing the container first turns a lever into a constraint.

References

16 CFR 1700.14(a)(29), Methacrylic acid. Liquid household products containing more than 5 percent methacrylic acid by weight to volume in a single retail package require special packaging, except products applied by an absorbent material contained inside a dispenser such as a pen-like marker, provided no free liquid is within the device and the acid will emerge only through the tip under any reasonably foreseeable conditions of use. law.cornell.edu
16 CFR 1700.14(a)(18), Glue removers containing acetonitrile: household glue removers in a liquid form containing more than 500 mg of acetonitrile in a single container. law.cornell.edu
16 CFR 1700.14(a)(15) on solvents for paint or other similar surface-coating material at 10 percent or more benzene, toluene, xylene or petroleum distillates under 100 SUS, and 16 CFR 1700.15, the poison prevention packaging standards: the packaging must keep working in actual contact with the substance and across the openings and closings customary for its size, at not less than 85 percent child-resistant effectiveness without a demonstration and 80 percent after one. law.cornell.edu
16 CFR 1500.14, Products requiring special labeling, whose paragraph (b)(3)(ii) requires the signal word "danger", the statement "Harmful or fatal if swallowed" and "Call physician immediately" for products at 10 percent or more petroleum distillates, because they may be aspirated into the lungs. law.cornell.edu
21 CFR 701.3, the cosmetic ingredient declaration, which requires ingredients in descending order of predominance on the label of a cosmetic in package form. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a salon. Whether a formula crosses 5 percent methacrylic acid or 500 mg of acetonitrile is a question about your formula and your container size, and the percentages here are the test rather than the answer. Nothing on these pages certifies a package as child-resistant.