Aerosol cosmetics labelling in the EU follows two rulebooks at once. Regulation (EC) 1223/2009 governs the product as a cosmetic, and the Aerosol Dispensers Directive 75/324/EEC governs the container as a pressurised package. Dry shampoo, hairspray, spray deodorant, sun spray and mousse all sit in this overlap, and the second rulebook is the one brands routinely miss.
The result is a pack that looks compliant to a cosmetic checklist and fails an inspection anyway, because it is missing the reverse epsilon, the pressure warnings or the nominal capacity in the required form. This guide sets out exactly what has to appear on an aerosol cosmetic, why the flame pictogram appears without CLP applying, and how spray format changes the safety assessment behind the pack.
Key takeaways
- Aerosol cosmetics must satisfy both the Cosmetic Regulation and the Aerosol Dispensers Directive, and the two lists of label elements do not overlap.
- The reverse epsilon marking is the aerosol conformity mark and must appear on every aerosol dispenser placed on the EU market.
- Pressure related safety phrases are mandatory even for non-flammable aerosols, including the warning that the container may burst if heated.
- Cosmetics in the finished state are outside the scope of CLP, so flammability labelling on a cosmetic aerosol comes through the aerosol directive rather than through CLP.
- The flame pictogram and signal word are still required where the aerosol is classified as flammable or extremely flammable.
- Spray format changes the safety assessment, because inhalation exposure has to be evaluated and some ingredients carry restrictions against sprayable applications.
- Aerosols are dangerous goods in transport, which affects carriers, e-commerce fulfilment and airfreight regardless of cosmetic status.
The two rulebooks side by side
It helps to see which requirement comes from where, because the two sets are enforced by different authorities and appear in different parts of the artwork.
| Label element | Source | Notes |
|---|---|---|
| Responsible Person name and EU address | Cosmetic Regulation Article 19 | Plus country of origin for imported products |
| Nominal content, function, ingredient list, PAO or date of minimum durability, batch | Cosmetic Regulation Article 19 | Standard cosmetic set |
| Reverse epsilon marking | Aerosol Dispensers Directive | The conformity mark specific to aerosol dispensers |
| Name and address of the person responsible for marketing the aerosol | Aerosol Dispensers Directive | Usually the same entity as the Responsible Person |
| Pressure safety phrases | Aerosol Dispensers Directive | Required for all aerosols, flammable or not |
| Flame pictogram, signal word, flammability statements | Aerosol Dispensers Directive | Where the aerosol is classified flammable or extremely flammable |
The cosmetic elements are covered in our guides to cosmetic product labelling and the mandatory symbols. The aerosol elements are the ones that need adding on top.
The pressure warnings every aerosol needs
Regardless of the contents, an aerosol dispenser is a pressurised container, and the directive requires warnings that reflect that. The standard set covers:
- A statement that the container is pressurised and may burst if heated.
- Instructions to keep away from heat, hot surfaces, sparks, open flames and other ignition sources, with a no smoking instruction for flammable products.
- A prohibition on piercing or burning the container, even after use.
- Protection from sunlight and a temperature ceiling, typically expressed as do not expose to temperatures exceeding 50 degrees Celsius.
- Keep out of reach of children.
- For flammable aerosols, a warning not to spray on an open flame or other ignition source.
These have to appear in the language of every Member State where the product is sold, which is where multi market artwork usually runs out of space. Reducing the type size below legibility is not a solution, and neither is moving the warnings to an outer carton that the consumer discards.
Because cosmetics are excluded from the scope of CLP in their finished state, a cosmetic aerosol does not need a UFI code or a poison centre notification. The hazard elements you see on a hairspray can are there because the aerosol directive requires them, not because CLP applies. The distinction matters when someone asks you for a UFI you do not need to have.
How aerosols are classified as flammable
Aerosol classification depends on the flammable content of the formulation and the behaviour of the spray, assessed through recognised ignition distance and enclosed space methods. In practice, three categories exist: extremely flammable, flammable and non-flammable, and the classification determines the pictogram and the wording.
For cosmetic aerosols the flammable content is usually ethanol, a hydrocarbon propellant such as propane or butane, or both. Two consequences follow:
- Reformulating to reduce flammability changes the spray. Compressed gas propellants such as nitrogen give a different spray pattern and a falling pressure through the life of the can, which affects consumer perception more than most brands expect.
- The classification decision belongs with the filler. Contract aerosol fillers hold the data and the equipment for the classification, and they should provide it in writing. Do not assume it because a similar product carries a particular pictogram.
Aerosols are dangerous goods in transport. Couriers, airlines and marketplaces apply their own restrictions, and many e-commerce fulfilment centres refuse them or charge a surcharge. If your route to market is online, confirm your carrier will handle aerosols before you tool the packaging, not after your first shipment is rejected.
What changes in the safety assessment
A spray is not just a different pack. The safety assessment has to consider a route of exposure that a cream does not have.
Inhalation exposure
The assessor needs the spray characteristics, including droplet size distribution where available, the amount of product released per second, the typical use pattern and the room volume assumptions. Fine droplets that can reach the lower airways change the exposure calculation substantially, which is why pump sprays and aerosols with very fine mists attract more scrutiny than a coarse spray.
Ingredients restricted in sprayable applications
Several annex entries carry conditions prohibiting use in applications that could lead to exposure of the end user’s lungs by inhalation. Nano UV filters are the clearest example, as our guide to nanomaterials in cosmetics explains, but the same wording appears elsewhere. An ingredient that is perfectly acceptable in a lotion can be prohibited in the spray version of the same product.
Anhydrous formulation questions
Most aerosol cosmetics are anhydrous or very low in water, which changes the preservation question and the stability profile. Our note on anhydrous cosmetics covers how that affects the file, and the same logic applies to sprays built on alcohol.
A practical launch sequence
For a new aerosol cosmetic, the order of work matters:
- Choose the propellant system early, because it drives flammability classification, transport and the safety assessment together.
- Get the classification in writing from the filler, along with the fill data.
- Commission the safety assessment with the spray characteristics included, not as an afterthought.
- Build artwork against both rulebooks, checking the aerosol elements separately from the cosmetic ones.
- Confirm carrier and marketplace acceptance before committing to a launch date.
- Notify through the CPNP as normal, including the frame formulation.
If your range mixes formats, keep separate artwork checklists. The most common failure we see is a spray version of an existing product using the artwork template from the lotion, with the entire aerosol block missing.
Bringing it all together
Aerosol cosmetics are not harder than other products, they are simply governed by one more instrument than most brands realise. The Cosmetic Regulation covers what is inside, the Aerosol Dispensers Directive covers the fact that it is under pressure, and the two together produce a longer label than any single checklist will generate.
Get the propellant decision made first, get the flammability classification in writing from your filler, make sure the safety assessment addresses inhalation, and build the artwork from both rulebooks. The remaining risk is logistical rather than regulatory, and it is worth resolving before your packaging is ordered.
Lexora assesses aerosol and spray cosmetics, including the inhalation exposure work, and checks artwork against both the cosmetic and aerosol requirements. Start with the anhydrous and alcohol-based cosmetic safety package, or have the pack checked with a cosmetic label review.
Frequently asked questions
What is the reverse epsilon on an aerosol can?
It is the conformity marking required by the Aerosol Dispensers Directive, indicating that the dispenser meets the directive’s requirements. It must appear on every aerosol dispenser placed on the EU market, legibly and indelibly, and it is separate from any cosmetic labelling requirement.
Does a cosmetic aerosol need a UFI code?
No. Cosmetic products in the finished state intended for the final user are excluded from the scope of the CLP Regulation, so there is no UFI and no poison centre notification. The hazard wording and pictogram on a cosmetic aerosol are required by the Aerosol Dispensers Directive instead.
Do non-flammable aerosols need warnings?
Yes. The pressure related phrases apply to all aerosol dispensers, including the warning that the container is pressurised and may burst if heated, the prohibition on piercing or burning it, and the temperature limit. Only the flammability specific elements depend on classification.
Can I use nano titanium dioxide in a sun spray?
Not where the annex entry prohibits applications that could lead to exposure of the lungs by inhalation, which is the case for the nano UV filter entries. If a spray format is essential, the filter system has to be chosen accordingly, and that decision belongs at formulation stage rather than at packaging stage.
How does spray format change the safety assessment?
It adds inhalation as a route of exposure. The assessor needs the spray characteristics, including droplet size where available, the quantity released per use and realistic use assumptions, then evaluates whether the inhalable fraction is acceptable. A fine mist is assessed more conservatively than a coarse spray.
Can I ship aerosol cosmetics by post?
Only within the rules for dangerous goods, and many carriers and marketplaces restrict or refuse them. Airfreight is particularly restricted. Confirm acceptance with your logistics partners before you commit to an aerosol format, because the restriction affects your route to market rather than your paperwork.
