Anyone who places aerosols on the market, whether as a manufacturer, importer or retailer with an own brand, bears responsibility for the labelling. In Germany, aerosol can labelling is governed by several complementary sets of rules: product safety law for aerosol dispensers, chemicals law for hazardous mixtures and the regulations for prepackages. This guide provides an overview of the most important mandatory information. It does not replace legal advice; the current text of the respective regulation is authoritative, and in case of doubt you should consult a qualified body.

Legal basis for aerosol can labelling

Aerosolpackungsverordnung (13. ProdSV)

The Aerosolpackungsverordnung (German Aerosol Dispensers Ordinance) is the Thirteenth Ordinance under the Produktsicherheitsgesetz (German Product Safety Act). It transposes the EU Aerosol Dispensers Directive 75/324/EEC into German law. The ordinance defines how an aerosol dispenser must be constructed, which tests take place before placing on the market and which information must appear on the dispenser.

CLP Regulation (EC) No 1272/2008

The CLP Regulation governs the classification, labelling and packaging of substances and mixtures in the EU. Aerosols with flammable propellants or hazardous ingredients fall under it. The CLP Regulation determines hazard pictograms, signal word, hazard statements (H statements) and precautionary statements (P statements) as well as the design of the label.

Further regulations

The fill quantity declaration is subject to weights and measures law with the Fertigpackungsverordnung (German Prepackages Ordinance). For products containing volatile organic compounds, such as paints, additional information on the VOC content may be required.

Mandatory information under the Aerosolpackungsverordnung

Under the Aerosolpackungsverordnung, every aerosol dispenser must bear at least the following information in visible, legible and indelible form:

Name and address or registered trade mark of the person placing the aerosol dispenser on the market (placer on the market).
Conformity mark in the form of the reversed epsilon. It confirms that the dispenser meets the requirements of the directive.
Filling batch details that allow the filling lot to be identified (batch marking).
Nominal content by volume, and for certain products additionally by mass.
Flammability information, where the contents are classified as flammable, including a statement of which mass of the contents is flammable where this is required.
Pressure warnings, in particular that the container is pressurised, must be protected from sunlight and temperatures above 50 °C and must not be forcibly opened or burned even after use.
Additional operating and hazard notes required for the safe use of the product, such as "Do not spray on a naked flame or any incandescent material".

Many of these notes coincide with P statements under the CLP Regulation, so in practice they appear together in the labelling field.

Labelling under CLP

An aerosol classified as hazardous bears a label with the following elements:

Element	Content	Example for flammable aerosols
Product identifier	Trade name and naming of the ingredients relevant to classification	Product name plus solvent or propellant according to classification
Hazard pictograms	Red-bordered diamonds with symbol	Flame (flammable), where applicable exclamation mark or health hazard
Signal word	"Danger" or "Warning"	"Danger" for extremely flammable aerosol
H statements	Hazard statements	Extremely flammable aerosol; Pressurised container: May burst if heated
P statements	Precautionary statements on prevention, response, storage, disposal	Keep away from heat, sparks, open flames; Do not pierce or burn; Protect from sunlight
Supplier details	Name, address, telephone number	Company details of the placer on the market
Nominal quantity	For supply to consumers	Fill quantity in ml

Flammability is classified according to the criteria of the CLP Regulation in categories from extremely flammable to non-flammable and is based on the chemical heat of combustion and the results of the flammability tests for aerosols. Which category applies follows from the formulation and propellant and is documented in the safety data sheet.

Typical notes on technical sprays

On technical sprays with flammable propellants, the following information regularly appears on the label:

Pressurised container: May burst if heated.
Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking.
Do not spray on an open flame or other ignition source.
Do not pierce or burn, even after use.
Protect from sunlight. Do not expose to temperatures exceeding 50 °C.
Keep out of reach of children.
Information on inhalation of vapours, eye and skin contact depending on classification.

Which statements are mandatory in each case follows from the classification of the specific mixture. The exact wording is prescribed in the CLP Regulation and must not be formulated freely.

Language and design requirements

The labelling must be in the official language of the member state in which the product is placed on the market, which in Germany means German. Multilingual labels are permitted if all languages contain the same information. Pictograms have minimum sizes depending on the package size, and the label must stand out from the background and be clearly legible. For small can sizes, the regulation provides for relief.

Fill quantity, batch and placer on the market in practice

The fill quantity is stated as the nominal volume, usually in millilitres for technical aerosols. The batch marking is usually printed or embossed on the base of the can or forms part of the label. It is the prerequisite for traceability: in the event of a complaint or a recall, it must be possible to determine which filling is affected.

The placer on the market is whoever offers the product under their own name or brand. In the case of an own brand, this is usually the retailer or brand owner, not the contract filler. This role entails obligations: the safety data sheet must be up to date and matched to the formulation, and for mixtures with hazardous properties, notifications to the competent bodies, such as the poison information centres, must be observed.

Disposal of completely emptied cans

Different routes apply to disposal:

Completely emptied cans from private use belong in recyclable waste collection, such as the yellow bin or yellow bag, since the tinplate or aluminium can is recycled as material. Completely emptied means that no product and no propellant escapes when the valve is actuated.
Cans that are not completely emptied must be disposed of as hazardous waste via the municipal hazardous waste collection.
Commercial users are subject to commercial waste law and dispose of cans via their waste disposal contractors with the appropriate waste code.

A disposal note on the label makes it easier for the user to choose the correct route.

Note on the EU Packaging Regulation and the Green Dot

With the EU Packaging and Packaging Waste Regulation (PPWR), the requirements for packaging labelling are changing step by step. Among other things, information on the material composition of packaging is being harmonised, and the use of marks that suggest an environmental claim beyond participation in take-back systems is being restricted. Under this regulation, the Green Dot logo may no longer be used on packaging from 2027. Anyone redesigning labels or planning own brands should already stop including the logo and plan label stocks accordingly. The specific deadlines and transitional arrangements follow from the text of the regulation.

Checklist for label review

Placer on the market with name, address and telephone number present?
Conformity mark (reversed epsilon) and batch marking present?
Nominal fill quantity stated?
Classification up to date and pictograms, signal word, H and P statements complete?
Pressure and flammability notes in the prescribed wording?
German language, minimum sizes and legibility observed?
Disposal note included, no Green Dot on new labels?
Safety data sheet matching the formulation and the label?

Labelling for own brands from Aerosols Germany

Aerosols Germany, the spray brand of Berger & Schröter GmbH, has technical sprays produced by partner plants in Europe, carries out quality control and dispatch in Iserlohn and supports retailers and brand owners with the labelling of their own brands. Classification and safety data sheet are available for every formulation, the mandatory information is incorporated into the label design and checked before series filling.

Are you planning an own brand or would you like to bring existing labels up to date? Then send your enquiry to Aerosols Germany and we will accompany you from classification to the approved label.

Aerosol can labelling: mandatory information on aerosol dispensers