EN    EN  COMMISSION OF THE EUROPEAN COMMUNITIES  
Brussels,  
COM(200 7) yyy final  
  
Proposal for a  
COMMISSION DIRECTIVE …./…/EC  
of […]  
amending , for the purposes of adapting to technical progress , Council Directive 
75/324/EEC on  the approximation of the laws of the Member States relating to aerosol 
dispensers  
EN  
EN 2   EN Proposal for a  
COMMISSION DIRECTIVE ../…/EC  
of […] 
amending , for the purposes of adapting to technical progress , Council Directive 
75/324/EEC on the approximation of the  laws of the Member States relating to aerosol 
dispensers  
(Text with EEA relevance)  
THE COMMISSION OF THE EUROPEAN COMMUNITIES,  
Having regard to the Treaty establishing the European Community,  
Having regard to Council Directive 75/324/EEC of 20 May 1975 on  the approximation of the 
laws of the Member States relating to aerosol dispensers1, and in particular Article s 5 and 
10(3)  thereof,  
Whereas:  
(1) Technical progress and innovation have made possible the placing on the market of an 
increasing number of aerosol dispensers with a complex technical design and 
characteristics different from  the traditiona l ones. However, the provisions of 
Directive 75/324/EEC are not sufficient to guarantee a high level of safety  for such 
non-traditional aerosol dispensers . The indi vidual design of non -traditional aerosols 
may create safety hazards that are not addressed by the safety provisions of the 
Directive, which are adapted to the known design of traditional aerosols. Therefore, a 
hazard analysis is necessary to be performed b y the manufacturer in order to cover all 
safety aspects  adequately . 
(2) Where appropriate t he hazard analysis must  address the risk resulting from the 
inhalation of the spray ejected by the aerosol dispenser  under normal or reasonably 
foreseeable conditions of  use, taking into account droplet size and size distribution in 
conjunction with physical and chemical properties of the contents , as the inhalation of 
small aerosol droplets may give rise to adverse health effects for the user under such 
conditions of use , even if the aerosol dispenser is prope rly classified and labelled 
according to the provisions of Directive 1999/45/EC of the European Parliament and 
of the Council of 31 May 1999 concerning the approximation of the laws, regulations 
                                                
1 OJ L 147, 9.6.1975, p. 40 . Directive as last amended by Council Regulation (EC) No 807/2003  (OJ L 
122, 16.5.2003, p. 36).   
EN 3   EN and administrative pr ovisions of the Member States relating to the classification, 
packaging and labelling of dangerous preparations2. 
(3) The safeguard clause provided for in Article 10 of Directive 75/324/EEC has been 
applied by one Member State. The safeguard measure adopted is  justified in view of 
the risk of flammability raised, under normal or reasonably foreseeable conditions of 
use, by the substances contained in the aerosol dispenser.  
(4) The current definition of flammable contents is not sufficient to guarantee a high level 
of safety  in all cases . In particular , although some contents dispersed by aerosol 
dispensers are not defined as “flammable ” according to the criteria listed in Annex VI 
to Council Directive 67/548/EEC  of 27 June 1967 on the approximation of laws, 
regulati ons and administrative provisions relating to the classification, packaging and 
labelling of dangerous substances3, they may lead to ignition under normal or 
reasonably foreseeable conditions of use of the aerosol dispenser.  Furthermore, t he 
current criter ia for flammability only address chemical substances and preparations 
and do not take properly into account special physical conditions of an aerosol spray 
or specific conditions of use.  
(5) In order to achieve the optimal level of safety and considering the s pecificities of 
aerosol dispensers, the new  criteria for the classification of the flammability of aerosol 
dispensers should also address the hazards relating to the dispersion of the contents of 
aerosol dispensers and the specific conditions of use of the  aerosol dispensers  rather 
than only the physical and chemical properties of the contents themselves . 
(6) The provisions of Directive 75/324/EEC currently in force require that each filled 
aerosol dispenser be immersed in a bath of hot water  in order to assess  its leak 
tightness and burst resistance . However, heat sensitive aerosol dispensers cannot 
withstand this test. Technological progress has made possible alternative test methods 
for the final assessment of aerosol dispensers for burst resistance and leak tightness , 
which guarantee the same level of safety . 
(7) The provisions of Directive 75/324/EEC currently in force provide for the possibility 
to use a test system enabling a result equivalent to that of the water bath method, 
subject to the agreement of the C ommittee referred to in Article 6. However, this 
procedure appears to be extremely heavy to be implemented in practice, and therefore, 
it has never been used. Therefore, in order to enable economic operators to benefit 
from technological progress without c ompromising the current level of safety by 
guaranteeing the appropriate technical expertise, it is necessary that the alternative test 
methods are approved, instead of the Committee referred to in Article 6 of the 
Directive, by the relevant competent autho rities designated by Member States under 
Council Directive 94/55/EC on the approximation of the laws of the Member States 
with regard to the transport of dangerous goods by road 4. 
                                                
2 OJ L 200, 30.7.1999, p.1. Dir ective as last amended by Commission Directive 2006/8/EC (OJ L 19, 
24.1.2006, p.12).  
3 OJ L 196, 16.8.1967, p. 1 . Directive as last amended by  Commission Directive 2004/73/EC (OJ L 152, 
30.4.2004, p. 1).  
4 OJ L 319, 12.12.1994,  p. 7. Directive as last amen ded by Commission Directive 2006/89/EC (OJ L 305, 
4.11.2006, p.4).   
EN 4   EN (8) Safety concerns have been raised following th e burst and leak of metal aeros ol 
dispensers heated to high temperatures, as is the case in cars expo sed to solar 
radiation. It is therefore necessary to limit the maximum filling level to the same value 
for all types of aerosol dispensers.  
(9) Most environmentally friendly and non -flammabl e propellants are compressed gases. 
However, the loss of pressure of aerosol dispensers using compressed gas propellants 
at the end of their life -time typically leads to a less efficient yield of contents. 
Consequently, the use of compressed gases as prope llants should be encouraged by 
increasing the maximum internal pressure of aerosol dispensers, to the extent that it is 
safe for the consumer.  
(10) Directive 75/324/EEC should therefore be amended accordingly.  
(11) The measures provi ded for in this Directive are in accordance with the opinion of the 
Committee on the adaptation to Technical Progress of the Directive on aerosol 
dispensers , 
HAS ADOPTED THIS DIRECTIVE:  
Article 1  
Directive 75/324/EEC is amended as set out in the Annex to this Directive.  
Article 2  
1. Membe r States shall adopt and publish by… {18 months from the entry  into force } 
the laws, regulations and administrative provisions necessar y to comply with this 
Directive . They shall forthwith communicate to the Commission the text of those 
provisions and a cor relation table between those provisions and this Directive . 
Member States shall apply those provisions as from {6 months from the deadline for 
transposition} . 
When Member States adopt those provisions, they shall contain a refer ence to this 
Directive or be accompanied by such a reference on  the occasion of their official 
publication. Member States shall determine how such a reference is to be made.  
2. Member States shall communicate to the Commission the texts of the main 
provisions of national law which th ey adopt in the field covered by this Directive.  
Article 3 
This Directive shall enter into force on the twentieth day following the date of its publication 
in the Official Journal of the European Union . 
Article 4 
This Directive is addressed to the Member S tates.   
EN 5   EN Done at Brussels, […] 
 For the Commission  
 […] 
 Member of the Commission   
EN 6   EN ANNEX  
Directive 75/324/EEC is hereby amended as follows:  
(1) In Article 8 the following paragraph  1a is added:  
“1a. Where an aerosol dispenser contains flammable components as  defined in 
point 1.8 of the Annex but the aerosol dispenser is not considered as “flammable” or 
“extremely flammable” according to the criteria set out in point 1.9 of the Annex, the 
quantity of flammable material contained in the aerosol dispenser must b e stated 
clearly on the label, in the form of the following legible and indelible wording: “X% 
by mass of the contents are flammable”.  
(2) Article 9a is re pealed.  
(3) The Annex is amended as follows:  
(a) Point 1.8 . is replaced by the following : 
“1.8. Flamm able contents  
Contents of aerosols shall be considered as flammable if they contain any component 
which is classified as flammable:  
(a) flammable liquid means a liquid having a flash point of not more than  93°C.  
(b) flammable solid means a solid substance or mixture which is readily 
combustible, or may cause or contribute to fire as a result of friction. Readily 
combustible solids are powdered, granular, or pasty substances or mixtures 
which are dangerous if they can be easily ignited by brief contact with an 
ignition source, such as a burning match, and if the flame spreads rapidly.  
(c) flammable gas means a gas or gas mixture having a flammable range with air 
at 20°C and a standard pressure of 1,013  bar. 
This definition does not cover pyrophoric, self -heating or water -reactive substances 
and mixtures , which shall never  be components of aerosol contents .” 
(b) The following point 1.9 . is inserted:  
“1.9. Flammable aerosols  
For the purpose of this Directive, an aerosol is considered as  ‘non -flammable’,  
‘flammab le’ or ‘extrem ely flammable’ according to its  chemical heat of combustion 
and mass content of flammable component s, as follows:  
(a) The aerosol is classified as ‘extremely flammable’ if it contains 85% or more 
flammable components and the chemical heat of combustion exceeds or is 
equal to 30  kJ/g;   
EN 7   EN (b) The aerosol  is classified as ‘non-flammable ’ if it contains 1% or less 
flammable components and the chemical heat of combustion is less than 
20 kJ/g.  
(c) All other a erosols  will be submitted to the following f lammability classification 
procedures or shall be classified as ‘extremely flammable’.  The ignition 
distance test, the enclosed space test and the foam flammability  test shall 
comply with point 6.3 . 
1.9.1. Flammable spray aerosols  
In the case of spray aero sols the classification shall be made taking into account the 
chemical heat of combustion and on the basis of the results of the ignition distance 
test, as follows:  
(a) If the chemical heat of combustion is less than 20  kJ/g:  
(i) The aerosol is classified as ‘flammable’ if ignition occurs at a 
distance equal or greater than 15  cm but less than 75  cm; 
(ii) The aerosol is classified as ‘extremely flammable’ if ignition 
occurs at a distance of 75  cm or more;  
(iii) If no ignition occurs in the ignition distance  test, the enclosed 
space test shall be performed and in this case, the aerosol is 
classified as ‘flammable ’ if the time equivalent is less than or equal 
to 300  s/m3 or the deflagration density is less than or equal to 
300 g/m3; otherwise the aerosol is classified as ‘non-flammable ’; 
(b) If the chemical heat of combustion is equal to or more than 20  kJ/g, the aerosol 
is classified as ‘extremely flammable’ if ignition occurs at a distance of 75  cm 
or more; otherwise the aerosol is classified as ‘flammable’.  
1.9.2. Flammable foam aerosols  
In the case of foam aerosols, the classification shall be made on the basis of the 
results of the foam flammability test.  
(a) The aerosol product shall be classified as ‘extremely flammable’ if:  
(i) the flame height is 20  cm or more and the flame duration is 2  s or 
more;  
or 
(ii) the flame height is 4  cm or more and the flame duration is 7  s or 
more.  
(b) The aerosol product which does not meet the criteria in (a) is classified as 
‘flammable’ if the flame height is 4  cm or more and the flame duration is 2  s or 
more. ”  
EN 8   EN (c) The following point 1.10 . is inserted:  
“1.10. Chemical Heat of Combustion  
The chemical heat of combustion DHc shall be either determined by  
(a) acknowledged rules of technology, described e.g. in standards such a s ASTM D 
240, ISO 13943 86.1 to 86.3 and NFPA 30B, or found in the scient ifically 
established literature  
or 
(b) applying the following calculation method:  
The chemical heat of combustion ( DHc), in kilojoules per gram (kJ/g), can be 
calculated as the produc t of the theoretical heat of combustion ( DHcomb), and a 
combustion efficiency, usually less than 1.0 (a typical combustion efficiency is 0.95 
or 95%).  
For a composite aerosol formulation, the chemical heat of combustion is the 
summation of the weighted hea ts of combustion for the individual components, as 
follows:  
[ ] ∑ Δ× =Δn
iic i c H w H)( %  
where:  
DHc = chemical heat of combustion (kJ/g) of the product;  
wi% = mass fraction of component i in the product;  
DHc(i) = specific heat of combustion (kJ/g) of component i in the product.  
The person responsible for the marketing of the aerosol dispenser has to describe the 
method used for determining the chemical heat of combustion in a document to be 
made readily available in an official Community language at the address specified 
on the label  in accordance with point (a) of Article 8(1), if the chemical heat of 
combustion is used as a parameter for assessing the flammability of aerosols 
according to the provisions of this Directive.”  
(d) The following provision is inserted after point 2 . “Gene ral provisions” and before 
point 2.1.  
“Without prejudice to specific provisions of th e Annex  on requirements  related to the 
flammability and pressure hazard , the person responsible for the marketing of 
aerosol dispensers is under an obligation to analyse t he hazards in order to identify 
those which apply to his aerosol dispensers.  Where appropriate, this analysis shall 
include a consideration of  the risks resulting from the inhalation of the spray ejected 
by the aerosol dispenser under normal and  reasonably  foreseeable conditions of use, 
taking into account droplet size distribution in conjunction with physical and  
EN 9   EN chemical properties of the contents.  He must then design, construct and test it and, if 
applicable, draft special statements concerning its use, taking account of his 
analysis.”  
(e) Point 2.2(b) is replaced by the following:  
“(b) Where  the aerosol  is classified as  ‘flammable ’ or ‘extremely flammable’ 
according  to the criteria of point 1.9 : 
– The flame symbol, in accordance with the model in Annex II to Directive 
67/548/EEC ; 
– The indication  ‘flammable ’ or ‘extremely flammabl e’, depending on the 
classification of the aerosol as ‘flammable’ or ‘extremely flammable’ .” 
(f) Point 2.3(a)  and 2.3(b) are  replaced by the following:  
“(a) Whatever its contents , an y additional operating precautions which alert 
consumers to the specific dangers of the product; if the aerosol dispenser is 
accompanied by separate instructions for use, the latter must also refl ect such 
operating precautions;  
(b) Where the aerosol is cla ssified as ‘flammable’ or ‘extremely flammable’ 
according to the criteria of point 1.9 , the following warnings:  
– The safety phrases  S2 and S16 laid down in An nex IV to Directive 
67/548/EEC;  
– ‘Do not spray on a naked flame or any incandescent material’.”  
(g) The following point 2.4. is inserted : 
“2.4. Volume of the liquid phase  
The volume of the liquid phase at 50°C must not exceed 90% of the net capacity.”  
(h) Point 3.1.2 . is replaced by the following:  
“3.1.2 . Filling  
At 50ºC, the pressure in the aerosol dis penser must not exceed 12 bar.  
However, if the aerosol does not contain a gas or mixture of gases having  a 
flammable range with air at 20°C and a standard pressure of 1 ,013 bar, the 
maximum allowable pressure at 50°C is 1 3,2 bar.”  
(i) Points 3.1.3 ., 4.1.5 . and 4.2.4 . are deleted.  
(j) Point 6.1.4 . is replaced by the following:  
“6.1.4 . Final inspection of filled aerosol dispensers  
6.1.4.1 . Aerosol dispensers shall be subject to one of th e following final test methods.   
EN 10   EN (a) Hot water bath test  
Each filled aeros ol dispenser shall be immersed in a hot water bath.  
(i) The temperature of the water bath and the duration of the test shall 
be such that the internal pressure reaches that which would be 
exerted by its contents at a uniform temperature of 50°C.  
(ii) Any a erosol dispenser showing visible permanent distortion or a 
leak must be rejected.  
(b) Hot final test methods  
Other methods for heating the contents of aerosol dispensers may be used if they 
guarantee that the pressure and temperature in each filled aerosol  dispenser reach 
the values required for the hot water bath test and distortions and leaks are detected 
with same precision as in the c ase of the hot water bath test.  
(c) Cold final test methods  
An alternative cold final test method may be used if it is in  accordance with the  
provisions o f an alternative m ethod  to the hot water bath test  for aerosol dispensers 
specified in point 6.2.4. 3.2.2 of Annex  A to Directive 94/55/E C. 
6.1.4.2 . For aerosol dispensers the contents of which undergo a physical or 
chemical  transformation changing their pressure characteristics after 
filling and before first use, cold final test methods according to point 
6.1.4.1 (c) should be applied.  
6.1.4.3 . In case of test methods according to point s 6.1.4.1 ( b) and 6.1.4.1 (c): 
(a) The t est method must be approved by a competent authority  . 
(b) The person responsible for the marketing of aerosol dispensers must 
submit an application for approval to a competent authority. The 
application must be accompanied by the technical file describing  the 
method.  
(c) The person responsible for the marketing of aerosol dispensers must, for 
surveillance purposes, keep the approval of the competent authority, the 
technical file describing the method and, if applicable, control reports 
readily available at  the address specified on the label in accordance with 
point (a) of Article 8(1 ). 
(d) The technical file must be established in a n official  Community language 
or a certified copy thereof must be available.  
(e) ‘competent authority’ means the authority desi gnated in each Member 
State under Directive 94/55/EC.  
(k) The following point 6.3 . is inserted:   
EN 11   EN “6.3. Tests on the flammability of aerosols  
6.3.1.  Ignition distance test for spray aerosols  
6.3.1.1.  Introduction  
6.3.1.1.1.  This test standard describes the method to determine the ignition 
distance of an aerosol spray in order to assess the associated flame risk. 
The aerosol is sprayed in the direction of an ignition source at intervals 
of 15  cm to observe if ignition and sustained combustion of the spray 
takes place. Ignition and sustained combustion is defined as when a 
stable flame is maintained for at least 5  s. The ignition source is defined 
as a gas burner with a blue, non -luminous flame 4 -5 cm in height.  
6.3.1.1.2.  This test is applicable to aerosol pro ducts with a spray distance of 15  cm 
or more. Aerosol products with a spray distance of less than 15  cm such 
as dispensing foams, mousses, gels and pastes  or fitted with a metering 
valve, are excluded from this test. Aerosol products that dispense foams, 
mousses, gels or pastes  are subject to testing under the aerosol foam 
flammability test.  
6.3.1.2. Apparatus and material  
6.3.1.2.1 . The following apparatus is required:  
Water bath maintained at 20 °C accurate to ± 1°C 
Calibrated laboratory scales (balance)  accurate to ± 0.1 g  
Chronometer (stopwatch)  accurate to ± 0.2 s  
Graduated scale, support and clamp  graduations in cm  
Gas burner with support and clamp   
Thermometer  accurate to ± 1°C 
Hygrometer  accurate to ± 5% 
Pressure gauge  accurate to ± 0.1 bar  
6.3.1.3. Procedure  
6.3.1.3.1 . General requirements  
6.3.1.3.1.1 . Before testing, each aerosol dispenser shall be conditioned and then 
primed by discharging for approximately 1 s. The purpose of this action 
is to remove non -homogeneous m aterial from the diptube.  
6.3.1.3.1.2 . The instructions of use shall be strictly followed, including whether the 
dispenser is intended to be used in the upright or inverted position. When 
shaking is required, shake immediately before testing.   
EN 12   EN 6.3.1.3.1.3 . The test shall be carried out in a draught -free environment capable of 
ventilation, with the temperature controlled at 20°C ± 5°C and relative 
humidity in the range 30 - 80%.  
6.3.1.3.1.4 . Each aerosol dispenser is to be teste d: 
(a) when full according to the complete procedure, with the gas burner in the 
range of 15 - 90 cm distance from the actuator of the aerosol can;  
(b) when 10 - 12% full nominal (% by mass) only one test, either at 15 cm distance 
from the actuator when th e spray from a full can did not ignite at all, or at the 
flame ignition distance of the spray of a full can plus 15 cm.  
6.3.1.3.1.5 . During the test, the can shall be positioned as indicated by label 
instructions. The ignition source shall be positioned ac cordingly.  
6.3.1.3.1.6 . The following procedure requires testing the spray at intervals of 15 cm 
between the burner flame and the aerosol actuator, in the range of 15 - 
90 cm. It is efficient to start at 60 cm distance between burner flame and 
aerosol actu ator. The distance between burner flame and aerosol 
actuator shall be increased by 15 cm in the case of an ignition of the 
spray at 60 cm distance. The distance shall be decreased by 15  cm in the 
case of no ignition at 60 cm distance between burner flame a nd aerosol 
actuator. The aim of the procedure is to determine the maximum distance 
between aerosol actuator and burner flame that leads to sustained 
combustion of the spray or to determine that ignition could not be 
obtained at 15  cm distance between the b urner flame and the aerosol's 
actuator.  
6.3.1.3.2 . Test procedure  
(a) A minimum of 3 full aerosol dispensers per product shall be conditioned to 
20°C  ± 1°C with at least 95% of the dispenser immersed in the water for at 
least  30 min before each test (if the aerosol is fully immersed, 30  min 
conditioning is sufficient);  
(b) Comply with general requirements. Record the temperature and relative 
humidity of the environment;  
(c) Weigh an aerosol dispenser and note its mass;  
(d) Determine the internal pressure and initial discharge rate at 20°C ± 1°C (to 
eliminate faulty or partly filled aerosol dispensers);  
(e) Support the gas burner on a flat horizontal surface or fix the burner to a 
support by means of a clamp;  
(f) Ignite the gas burner; the flame shall be non -luminous and approximately  
4-5 cm high;   
EN 13   EN (g) Place the actuator's exit orifice at the required distance from the flame. The 
aerosol shall be tested in the position it is designed to be used, e.g. upright or 
inverted;  
(h) Leve l the actuator's orifice and burner flame, ensuring that the orifice is 
properly directed towards and aligned with the flame (see Figure 6.3.1.1). The 
spray shall be expelled through the top half of the flame;  
Figure 6.3.1.1. 
(i) Comply with the general r equirements regarding shaking of the dispenser;  
(j) Actuate the valve of the aerosol dispenser, to discharge its contents for 5  s, 
unless ignition occurs. If ignition occurs, continue discharging and time the 
duration of the flame for 5 s, from the start o f ignition;  
(k) Note the ignition results for the distance between the gas burner and the 
aerosol dispenser in the table provided;  
(l) If no ignition occurs during step (j), the aerosol shall be tested in alternative 
orientations, e.g. inverted for upright  use products, to check if ignition is 
obtained;  
(m) Repeat steps (g) to (l) twice more (a total of 3) for the same can at the same 
distance between the gas burner and the aerosol actuator;  
(n) Repeat the test procedure for another two aerosol cans of the same product at 
the same distance between gas burner and aerosol actuator;  
(o) Repeat steps (g) to (n) of the test procedure at a distance between 15 and 
90 cm between the actuator of the aerosol can and the burner flame depending 
on the outcome of each te st (see also 6.3.1.3.1.4 and 6.3.1.3.1.5);  
(p) If no ignition occurs at 15 cm, the procedure is finished for initially full cans. 
The procedure is also finished when ignition and sustained combustion is 
obtained at a distance of 90 cm. If ignition could no t be obtained at 15 cm 
distance, record that ignition did not occur. The maximum distance between 
burner flame and the aerosol's actuator for which an ignition and sustained 
combustion was observed is noted as the "ignition distance", in all other 
circumst ances;   
EN 14   EN (q) One test shall also be conducted on 3 cans of 10 - 12% nominal fill level. These 
cans shall be tested at a distance between the aerosol's actuator and the burner 
flame of "the flame ignition distance of full cans + 15 cm";  
(r) Discharge an aeros ol can to a 10 - 12% nominal fill level (by mass) in bursts 
of 30  s maximum. Observe a 300 s minimum time period between bursts. 
During this interim period dispensers shall be placed in the water bath for 
conditioning;  
(s) Repeat steps (g) to (n) for 10 - 12% nominal fill aerosol cans, omitting 
steps  (l) and (m). This test shall only be performed with the aerosol in one 
position, e.g. upright or inverted, corresponding with that which produced the 
ignition (if any) for filled cans;  
(t) Record all results in  the Table 6.3.1.1 as shown below.  
6.3.1.3.2.1  All experiments shall be performed in a fume hood in a room that may be 
well ventilated. Ventilation of the fume hood and room can be applied for 
at least 3 min after each test. Take all necessary safety preca utions to 
prevent the inhalation of combustion products.  
6.3.1.3.2.2 . The cans with a 10 - 12% nominal fill level shall be tested only once. The 
result tables need only one result per can indicated.  
6.3.1.3.2.3 . When the test in the position in which the d ispenser is designed to be 
used gives a negative result, the test shall be repeated in the position of 
the dispenser most likely to result in a positive result.  
6.3.1.4. Method of assessing results  
6.3.1.4.1 . All the results shall be recorded. Table 6.3.1.1 below shows the model of 
"result table" to be used. ”  
EN 15   EN Table 6.3.1.1. 
Date  Temper ature ______________ °C 
Relat ive humidity __________ % 
Name of product   
Net volume   Can 1  Can 2  Can 3  
Initial level of 
filling   % % % 
Dispenser  
distance  Test 1 2 3 1 2 3 1 2 3 
15 cm  Ignition?  
Y or N     
30 cm  Ignition?  
Y or N     
45 cm  Ignition?  
Y or N     
60 cm  Ignition?  
Y or N     
75 cm  Ignition?  
Y or N     
90 cm  Ignition?  
Y or N     
Observations – 
including can 
position      
6.3.2. Enclosed space ignition test  
6.3.2.1 Introduction  
This test standard describes the method to assess the flammability of products 
emerging from aerosol dispensers due to their propensity to ignite in an enclosed or 
confined space. The contents of an aerosol dispenser are sprayed into a cylind rical 
test vessel containing a burning candle. If an observable ignition occurs, the elapsed 
time and amount discharged is noted.  
6.3.2.2. Apparatus and material  
6.3.2.2.1 . The following apparatus is required:  
Chronometer (stopwatch)  accurate to ± 0.2 s  
Water bath maintained at 20  °C  accurate to ± 1°C   
EN 16   EN Calibrated laboratory scales (balance)  accurate to ± 0.1 g  
Thermometer  accurate to ± 1°C  
Hygrometer  accurate to ± 5%  
Pressure gauge  accurate to ± 0.1 bar  
Cylindrical test vessel  as detailed below  
6.3.2.2.2 . Preparation of test apparatus  
6.3.2.2.2.1 . A cylindrical vessel approximately 200 dm3 volume, approximately 600 
mm in diameter and approximately 720 mm long and open at one end 
shall be modified as follows:  
(a) A closure system consisting of a hinge d cover shall be matched to the open end 
of the receptacle; or  
(b) A plastic film 0.01 to 0.02 mm thick may be used as a closure system. If the test 
is carried out with a plastic film this must be used as described below:  
Stretch the film over the open end  of the drum and hold it in place with an 
elastic band. The strength of the band shall be such that when placed around 
the drum resting on its side, it stretches by only 25 mm when a mass of 0.45 kg 
is attached to its lowest point. Cut a 25 mm slit in the film, starting 50 mm from 
the edge of the drum. Ensure that the film is taut;  
(c) At the other end of the drum drill a 50 mm diameter hole 100 mm from the 
edge in such a way that the orifice is uppermost when the receptacle is laid 
down and ready for the t est (Figure 6.3.2.1.) 
Figure 6.3.2.1. 
  
±200 dm3 50 mm100 mm
 
(d) On a 200 ´ 200 mm metal support place a paraffin wax candle 20 to 40  mm in 
diameter and 100 mm high. The candle shall be replaced when having a height 
of less than 80 mm. The candle's flame is protected from the action of the spray  
EN 17   EN by a 150 mm wide, 200 mm high deflector. This includes the plane inclined at 
45° produced 150  mm from the base of the deflector (Figure 6.3.2.2.); 
Figure 6.3.2.2. 
45°150 mm
200 mm71 mm
200 mm150 mm
 
(e) The candle placed on the metal support shall be positioned midway b etween 
the two ends of the drum (Figure 6.3.2.3.); 
Figure  6.3.2.3. 
 
(f) The drum is laid on the ground or on a support at a spot where the 
temperature is between 15 °C and 25 °C. The product to b e tested will be 
sprayed within the drum of roughly 200 dm3 in which there will be a source of 
ignition.  
6.3.2.2.2.2  Usually, the product leaves the aerosol can at an angle of 90° relevant to 
the vertical axis of the can. The layout and procedure described  refers to 
this kind of aerosol product. In the case of unusually operating aerosols 
(e.g. vertical -spray aerosol dispensers) it will be necessary to record 
changes to equipment and procedures in accordance with good  
EN 18   EN laboratory practice, such as ISO/IEC 17 025:1999 General requirements 
for the competence of testin g and calibration laboratories.  
6.3.2.3. Procedure  
6.3.2.3.1 . General requirements  
6.3.2.3.1.1 . Before testing, each aerosol dispenser shall be conditioned and then 
primed by discharging for approxi mately 1 second. The purpose of this 
action is to remove non -homogeneous material from the diptube.  
6.3.2.3.1.2 . The instructions of use shall be strictly followed, including whether the 
dispenser is intended to be used in the upright or inverted position.  When 
shaking is required, shake immediately before testing . 
6.3.2.3.1.3 . The tests shall be carried out in a draught -free environment capable of 
ventilation, with the temperature controlled at 20°C ± 5°C and relative 
humidit y in the range 30 - 80%.  
6.3.2.3.2 . Test procedure  
(a) A minimum of 3 full aerosol dispensers per product shall be conditioned to 
20°C  ± 1°C in a water bath with at least 95% of the dispenser immersed in the 
water for at leas t 30 min (if the aerosol is fully immersed, 30 min conditioning 
is sufficient);  
(b) Measure or calculate the actual volume of the drum in dm3; 
(c) Comply with general requirements. Record the temperature and relative 
humidity of the environment;  
(d) Determ ine the internal pressure and initial discharge rate at 20°C  ± 1°C (to 
eliminate faulty or partly filled aerosol dispensers);  
(e) Weigh one of the aerosol dispensers and note its mass;  
(f) Light the candle and apply the closure system (cover or plastic fil m); 
(g) Place the aerosol dispenser actuator orifice 35 mm or closer for a wide spray 
product, from the centre of the entrance hole in the drum. Start the 
chronometer (stopwatch) and following the instructions for use of the product; 
direct the spray towar ds the centre of the opposite extremity (cover or plastic 
film). The aerosol shall be tested in the position it is designed to be used, e.g. 
upright or inverted;  
(h) Spray until ignition occurs. Stop the chronometer and note the time elapsed. 
Re-weigh the aerosol dispenser and note its mass;  
(i) Ventilate and clean the drum removing any residue likely to affect subsequent 
tests. Allow the drum to cool if necessary;   
EN 19   EN (j) Repeat the test procedure steps (d) to (i) for another two aerosol dispensers of 
the same  product (3 in total, note: each dispenser is only tested once);  
6.3.2.4. Method of assessing results  
6.3.2.4.1 . A test report containing the following information shall be drawn up:  
a) The product tested and its references;  
b) The internal pressure and di scharge rate of the aerosol dispenser;  
c) The temperature and relative air humidity of the room;  
d) For each test, the discharge time (s) needed to achieve ignition (if the product 
does not ignite, state this);  
e) The mass of the product sprayed during eac h test (in g);  
f) The actual volume of the drum (in dm3). 
6.3.2.4.2 . The time equivalent (t eq) needed to achieve ignition in one cubic metre 
can be calculated as follows:  
1000 x discharge time (s)   
teq =  
Actual volume of drum (dm3) 
6.3.2.4.3 . The defla gration density (D def) needed to achieve ignition during the test 
may also be calculated as follows:  
1000 x Amount of product dispensed  (g)  
Ddef = 
Actual volume of drum (dm3) 
6.3.3. Aerosol foam flammability test  
6.3.3.1. Introduction  
6.3.3.1.1 . This t est standard describes the method to determine the flammability of 
an aerosol spray emitted in the form of a foam, mousse, gel or paste. An 
aerosol, which emits a foam, mousse, gel or paste is sprayed (approx. 5 
g) on a watchglass and an ignition source (c andle, wax taper, match or 
lighter) is placed at the base of the watchglass to observe if ignition and 
sustained combustion of the foam, mousse, gel or paste occurs. Ignition 
is defined as a stable flame maintained for at least 2 s and a minimum 4 
cm in he ight. 
6.3.3.2. Apparatus and material  
6.3.3.2.1 . The following apparatus is required:  
Graduated scale, support and clamp  gradations in cm   
EN 20   EN Fire-resistant watchglass roughly 150 mm in diameter  
Chronometer (stopwatch)  accurate to ± 0.2 s  
Candle, wax taper,  match or lighter   
Calibrated laboratory scales (balance)  accurate to ± 0.1 g  
Water bath maintained at 20  °C  accurate to ± 1 °C 
Thermometer  accurate to ± 1 °C 
Hygrometer  accurate to ± 5%  
Pressure gauge  accurate to ± 0.1 bar  
6.3.3.2.2 . The watchglass i s placed on a fire -resistant surface within a draught -free 
area that may be ventilated after each test. The graduated scale is 
positioned exactly behind the watchglass and held vertically by means of 
a support and clamp.  
6.3.3.2.3 . The scale is positioned in such a way that its origin is on a level with the 
watchglass base in a horizontal plane.  
6.3.3.3. Procedure  
6.3.3.3.1 . General requirements  
6.3.3.3.1.1 . Before testing, each aerosol dispenser shall be conditioned and then 
primed by discharging for appro ximately 1 second. The purpose of this 
action is to remove non -homogeneous material from the diptube.  
6.3.3.3.1.2 . The instructions of use shall be strictly followed, including whether the 
dispenser is intended to be used in the upright or inverted positio n. When 
shaking is required, shake immediately before testing.  
6.3.3.3.1.3 . The tests shall be carried out in a draught -free environment capable of 
ventilation, with the temperature controlled at 20°C ± 5°C and relative 
humidity in the range of 30 –80%.  
6.3.3.3.2 . Test procedure  
(a) A minimum of four full aerosol dispensers per product shall be conditioned to 
20°C ± 1°C with at least 95% of the dispenser immersed in the water for at 
least 30  min before each test (if the aerosol is fully immersed, 30  min 
cond itioning is sufficient);  
(b) Comply with general requirements. Record the temperature and relative 
humidity of the environment;  
(c) Determine the internal pressure at 20°C ± 1 °C (to eliminate faulty or partly 
filled aerosol dispensers);   
EN 21   EN (d) Measure the dis charge or flow rate of the aerosol product to be examined, so 
that the amount of test product dispensed can be more accurately gauged;  
(e) Weigh one of the aerosol dispensers and note its mass;  
(f) On the basis of the measured discharge or flow rate and fo llowing the 
manufacturer's instructions, release approximately 5 g of the product onto the 
centre of the clean watchglass with the aim of producing a mound no higher 
than 25 mm;  
(g) Within 5 s of completion of discharge, apply the source of ignition to the  edge 
of the sample at its base and at the same time start the chronometer 
(stopwatch). If necessary, the ignition source shall be removed from the edge of 
the sample after approximately two seconds, in order to clearly observe if 
ignition has occurred. If  no ignition of the sample is apparent, the ignition 
source shall be reapplied to the edge of the sample;  
(h) If ignition occurs note the following points:  
(i) The maximum height of the flame in cm above the base of the watchglass;  
(ii) The flame duration in s; 
(iii) Dry and re -weigh the aerosol dispenser and calculate the mass of the 
released product;  
(i) Ventilate the test area immediately after each test;  
(j) If ignition is not obtained and the released product remains in the form of a 
foam or paste thro ughout its period of use, steps (e) to (i) shall be repeated. 
Allow the product to stand for 30 sec, 1 min, 2  min or 4 min before applying 
the ignition source;  
(k) Repeat the test procedure steps (e) to (j) twice more (a total of 3) for the same 
can; 
(l) Repeat the test procedure steps (e) to (k) for another two aerosol cans (3  cans 
in total) of the same product.  
6.3.3.4. Method of assessing results  
6.3.3.4.1 . A test report containing the following information shall be drawn up:  
(a) whether the product igni tes; 
(b) maximum flame height in cm;  
(c) duration of flame in s;  
(d) the mass of the product tested.