With the increasing market demand for products like CBD/THC oils, essential oils, wellness drops and flavor enhancers, packaging safety is playing an increasingly important role. Having a child injured due to faulty packaging is a tragedy and a worst-case scenario for any company.
That is why the Consumer Product Safety Commission (CPSC) requires the use of child-resistant closures — to protect the consumer and to protect your business. Tamper-evident packaging and child-resistant packaging are mandated in certain scenarios so it is important to understand if your products fall within those scenarios.
For safety compliance, there are certain activities your packaging distributor or product manufacturer must do and some activities you as the product seller need to do. But first, it’s important to understand the rules and the type of testing needed.
About Child-Resistant Packaging Closure Regulations
Please note that the following information is based on our understanding of child-resistant packaging laws here at Carow Packaging. As we are not attorneys, our expert views cannot be construed as legal opinions, such as in the court of law. At the same time though, we have conducted ample research to provide you with the following information.
Child-Resistant Closure Testing
When it comes to child-resistant packaging, the regulations for this type of packaging are mandated by the Consumer Product Safety Commission or CPSC. This is a federal organization that sets and enforces safety regulations for packaging.
When it comes to liquid dispensing packaging, the CPSC doesn’t endorse or approve any specific child-resistant closures. What they do provide is testing requirements to determine whether a child-resistant closure meets the legal standards.
Keep in mind that the CPSC testing protocol includes children and adults. This is to ensure that the packaging is difficult for children to open but not too difficult for senior adults. The Poison Prevention Packaging Act released by the CPSC includes the full testing guidelines for both groups.
In general, here is how they test various packaging products.
Testing for Child Resistance
The testing procedure starts with a group of 50 children. They have 5 minutes to try to open the closure. If a child doesn’t open the closure in the first 5 minutes, the tester shows the child how to open it. The child then has another 5 minutes to try again. If no more than 5 children in the first panel open the closure, it passes. If 15 or more children open it, the closure fails.
Testing for Senior Adult Accessibility
The CPSC requires senior adults as part of the testing because they’re the most likely group of adults to have difficulty with a child-resistant closure. The adult test group uses 100 people between the ages of 50 and 70.
Each person gets the packaging with instructions. The person has 5 minutes to open the closure and reclose it properly. If they succeed, they have 1 minute to do it again.
This testing procedure is meant to ensure that the closure is suitable for continued use. For a closure to pass, 90% of adults in the panel must open and properly close the package during both parts of the test.
If the primary packaging components pass the test, you are halfway to compliance. To receive CPSC approval, the filled product must pass protocol. Here’s where you come in.
Meeting Your End of the Safety Requirements
There are a few things you as the product seller need to do to stay compliant and protect your consumers and your business.
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- Choose the correct closure. When it comes to packaging for your liquid products, you’ll need to choose a closure for the bottle. The closure choices for drop dispensing are EuroDrop® or dropper pipettes.The cap you choose will depend on the neck of the bottle and the safety features needed. For example, the 18 DIN neck standard is the preferred bottle neck for essential oils.
There are four types of caps depending on your application and safety requirements.
- Regular
- Tamper-Evident (fit dropper bottles with 18DIN neck)
- Child-Resistant
- Child-Resistant & Tamper-Evident (fit dropper bottles with 18DIN neck)
We have been in the dispensing business for 30 years and know that it can be confusing deciding which primary packaging products or systems you may need for your product. We have tried to make it a little easier for you with our Buyer Guides. Please grab our Essential Oils Guide, CBD Dispensing Guide, and our Dropper Pipette Buyers Guide.
- Stay up to date on the latest regulations by the CPSC.
- Choose the correct closure. When it comes to packaging for your liquid products, you’ll need to choose a closure for the bottle. The closure choices for drop dispensing are EuroDrop® or dropper pipettes.The cap you choose will depend on the neck of the bottle and the safety features needed. For example, the 18 DIN neck standard is the preferred bottle neck for essential oils.
It is your duty, as the product seller, to know the latest regulations by the CPSC for child-resistant packaging. How do you do that?
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- Visit the CPSC website to look for the latest recalls, regulations, and resources.
- Call the CPSC at 800-638-2772 to ask any specific questions. The CPSC customer service reps are friendly and informative.
- Conduct protocol testing with reliable laboratories. This will give you a practical understanding of regulations and testing needed to achieve compliance.
- Speak to an attorney to develop a legal understanding of the subject so to know your rights and responsibilities. You will need to find an attorney who has knowledge and/or experience dealing with CPSC regulations.
- Ensure your packaging distributors’ or manufacturers’ product complied with CPSC regulations.
When you choose to work with a distributor or closure manufacturer, it’s your job is to make sure they understand the CPSC regulations for packaging safety. Before you place an order, you need to verify that those child-resistant closures comply with CPSC regulations. Ask to see the paperwork.The distributor should be fully transparent about their compliance with regulations. Some key points to address with your distributor and/or closure manufacturer for protocol tests include:
- Providing protocol test results and certification
- Conducting protocol tests for the closure and specified neck finish rather than the entire packaging
- Using the standard bottle for the protocol test to save time and money
Carow Packaging offers regular, push turn, child-resistant, tamper-evident, and child-resistant & tamper-evident caps. Whether your ultimate dispensing solution includes a cap and bottle, or a dropper pipette system, we have a full line of products that have passed the CPCS child safety compliance regulations.
- Test your filling and capping process.It’s not enough to show that the distributor or product manufacturer has met CPSC compliance regulations. The closure manufacturer has no control over compliance once the product is filled and capped. So, now it’s up to you. The most important part is that your filling and capping process apply the closure correctly.You, as the product seller, will need to commission the CPSC to test your final, filled product to prove the capping and filling processes were compliant with federal regulations.
In the case that there is an incident, the CPSC will require you to provide documentation to prove proper manufacturing and packaging processes were followed. This will require you or your filler/manufacturer to keep daily logs with recordings of torque, lot testing, and quantity inspected.
Note: If you sell internationally, specifically in Europe, the protocol testing is not the same as those required by the CPSC. In addition, the CPSC does not recognize the European protocols. Check with your country’s regulations to ensure your products are compliant.
Final Note
The above information is intended as a guide to help you get started working with proper child-resistant and/or tamper-evident caps and packaging products.
We also have a full time Quality Assurance Manager to help our customers troubleshoot any filling or capping issues that could lead to poor compliance results. To learn more about how important both product and process are to ensuring a quality product and how we could assist you, read this to learn more.
Additional questions or need some quick answers? Please give our Account Specialists a call to talk through your product application and safety compliance needs at 815-455-4600. We are happy to help.
