Australian and New Zealand harmonised labelling for aerosol products

1. Introduction

This information advises manufacturers of aerosol insecticide products about the harmonised aerosol labelling requirements of both the Agricultural Compounds and Veterinary Medicines Group (ACVM, New Zealand) and the Australian Pesticides and Veterinary Medicines Authority (APVMA, Australia).

This information is aimed primarily at manufacturers who wish to market a harmonised aerosol product in both countries. However, it can also be used for the labelling requirements for aerosol products marketed in only one of the 2 countries.

1.1. Harmonisation between New Zealand and Australia

The harmonised labelling requirements for aerosol products are aimed at satisfying the Australia – New Zealand Closer Economic Relations Trade Agreement. They are intended as a first step in achieving harmonisation on a growing number of products and registration requirements.

1.2. Definition of an aerosol

For the purposes of this guideline, an aerosol is an ‘agricultural chemical product’ (Australian definition) or a ‘pesticide product’ (New Zealand definition) that comprises an active constituent and a liquefied or compressed gas as a propellant, in a container with a suitable valve.

The aerosol products covered by the harmonised agreement and these harmonised labelling requirements include only those that:

• contain unscheduled constituents
• are defined as being either a space spray, a surface spray or a total release fogger (these terms are explained below)
• are developed and marketed primarily for use in domestic, commercial or industrial situations.

1.2.1. Space sprays

Space sprays can control both flying insects (when sprayed into the air) and crawling insects (when sprayed directly), but cannot be used to give lasting insecticidal activity on the surface.

1.2.2. Surface sprays

Surface sprays are designed to have their contents applied directly onto a surface or onto a crawling insect. They are used primarily for the control of crawling insects because they leave an insecticidal film that controls insect pests as they crawl over the surface. This group also includes those aerosol products that combine space and surface sprays; that is, they have a dual mode of action.

1.2.3. Total release foggers

Total release foggers are designed to release their total contents into the air in one application. They are primarily used to disinfest whole rooms or houses of pests such as fleas or cockroaches.

2. Label layout

This information should be read together with APVMA label content requirements, which also apply to aerosol product labelling.

2.1. Main panel and ancillary panels

A label panel refers to a distinct portion or division of the label. A label will be easier to read and follow if the necessary information is spread over at least 2 panels – the panels delineate the information, making it easier for a reader to identify important information. If space is limited, the print size may be too small and the layout may be cramped, making it difficult to convey intelligible, easily read information to the user.

Aerosol products generally contain at least 2 panels: a main panel (which is the most prominent) and ancillary panels. The main panel generally contains the following items:

• Product or trade name
• Active constituent statement
• Statement of claims for use
• Net contents

Any other items are included in the ancillary panels.

3. Explanatory notes: aerosol labels

The following notes outline the information required on aerosol labels and the format in which it should be presented.

3.1. Product name

The label must include the name of the chemical product. This does not have to be the same as the distinguishing name recorded in the APVMA Register for the chemical product.

Words, numbers, or phrases included in company logos or trademarks appearing adjacent to the product name are not automatically included as part of the name.

For a product name to be acceptable, it must:

• describe the usage for which the aerosol is intended. For example, it can include words and terms such as ‘household insecticide’, ‘flying insect killer’, ‘surface spray insecticide’
• be displayed in a manner that allows rapid and easy identification.

The product name must not:

• include misleading words or figures
• be offensive, or contain offensive words or phrases.

3.2. Use of terms such as ‘plus’, ‘extra strength’, ‘double strength’ or ‘professional strength’

Inclusion of ‘plus’, ‘extra strength’, ‘double strength’ or ‘professional strength’ or similar terms, whether in the product name or elsewhere on the label, is only acceptable if:

• there is a different registered aerosol product that has the same product name but does not include ‘plus’, ‘extra strength’, ‘double strength’ or a similar term
• use of such a term can be justified (for example, the product includes an additional active constituent that extends the use of a previously registered product, or the product has a higher level of an active constituent than a previously registered product).

3.3. Use of term 'low irritant'

Any claim that a product is ‘low irritant’ must be justified.

3.4. Active constituent and propellant statements

The active constituents and synergists (if present) are the substances that are primarily responsible for the killing action of the aerosol product. The propellant is the chemical that forces the contents from the aerosol container when the valve is opened.

All active constituents, synergists and propellants must be shown on the label.

3.4.1. Active constituent statement

3.4.1.1. Structure and position

An active constituent statement must:

• include the heading

Active constituent(s)

• be positioned below the product name on the main panel.

3.4.1.2. Use of common names

An active constituent must contain the common name of the substances as recommended by:

• Standards Australia in AS 1719-1994 or its revision, or as approved by Standards Australia for addition to the Standard
• International Organization for Standardization (ISO), or
• British Standards Institute (BSI).

Where no SA, ISO or BSI common name exists, the active constituent name should conform to the IUPAC (International Union of Pure and Applied Chemistry) system of nomenclature.

Some common names of active constituents in aerosol products include:

• allethrin
• bioallethrin
• bioresmethrin
• fenoxycarb
• hydroprene
• methoprene
• s-methoprene
• permethrin
• d-phenothrin
• propoxur
• pyrethrins
• tetramethrin.

3.4.1.3. Concentration

The concentration of each active constituent and synergist (if present) must be clearly stated in front of the name of the active constituent; for example:

ACTIVE CONSTITUENT: 2.79 g/kg PERMETHRIN,

(not PERMETHRIN 2.79 g/kg)

The concentration must be expressed in units of mass; that is, ‘g/kg’. It is acceptable to also include the concentration in ‘g/L’ in brackets next to 'g/kg'; for example:

2.79 g/kg (3.5 g/L) PERMETHRIN

The active constituents can be listed on the label in any order.

3.4.2. Propellant statement

A propellant statement must be included on the label. This statement can be on the main or the ancillary panel, and must include the heading:

Propellant

In most cases, an aerosol contains either butane, propane or some other liquid hydrocarbon. Therefore, the statement would be, for example:

Propellant: Hydrocarbon

3.5. Statements of claims of use

A brief statement of the purposes for which the aerosol product is to be used should be positioned immediately beneath the active constituent and propellant statements. However, if the product name sufficiently describes the use of the product, there is no need to include a separate statement of claims of use.

In some cases, pictures or diagrams may also be included as part of the statement of claims of use, provided they are consistent with the proper uses of the aerosol.

3.6. Net contents

Although the chemical within an aerosol container is in a liquid state, the convention is to state the net contents of an aerosol product in mass units. Therefore, the contents should be written in full or represented by the correct symbol (i.e. ‘grams’ or ‘g’).

You should also include the word:

NET

3.7. Company name and address

It is important that users of an aerosol can contact the person or company who is responsible for the product. To facilitate this, the label should include the name, street address and contact number of the product’s proprietor (registration holder). In addition, you may also include names and addresses of distributors or manufacturers.

A harmonised label must contain relevant names and addresses for both countries.

3.8. Directions for use

The directions for use should state clearly and concisely how, when and where the aerosol product is to be used. This information can be presented in the form of a table, points or text, and should be placed under the heading:

HOW TO USE

Some examples of statements that may be included in this section are shown below.

3.8.1. General

Shake can well before use.

Keep can in an upright position when spraying.

3.8.2. Space sprays

Close windows and doors, and spray high into the air for 3–5 seconds.

A quick burst in the direction of flying insects is sufficient.

Spray crawling insect directly.

3.8.3. Surface sprays

Spray directly onto insect for a quick kill.

Spray surfaces to be treated from about 15–20 cm away.

Generally, aerosol surface sprays control a range of crawling insect pests such as cockroaches, silverfish, ants, spiders, bedbugs, fleas, clothes moths and carpet beetles. If this is the case, the ‘How to use’ section should instruct the user how and where the aerosol is to be applied to treat for each type of pest.

3.8.4. Total release foggers

Place can on a raised surface (table or chair) with newspaper under can.

To release mist, point away from face and press down activator tab until it locks. Set in upright position then vacate premises for [x] hours.

Open door and windows for at least [x] minutes to ventilate area.

Use [x] cans for average size home and [y] cans for a larger home. Use additional cans for remote rooms where a full flow of mist is not assured.

3.8.5. Combination space and surface sprays

Combination sprays should have separate instructions for space treatment and for surface treatment. See the examples given above.

Avoid using statements inferring that the product controls ‘all pests’ rather than those specified. For example, the heading ‘To control flying insects’ infers that the product controls all flying insects, which is generally not the case. A more correct heading would be ‘To control most flying insects’.

3.9. Correct use statement

Immediately below the ‘How to use’ section, you must include the following statement, or a similar statement having the same meaning:

USE THIS PRODUCT ONLY AS DIRECTED

3.10. General instructions

General instructions should include any general information that is not already included in the directions for use.

3.11. Precaution statements

Precaution statements are intended to reduce any possible health risks to humans or animals due to possible exposure or contamination of food when the aerosol is used in the approved way. Such statements should be set out clearly under the heading:

PRECAUTIONS

Under the ‘Precautions’ heading, the following must be included on all aerosol labels as the first statement:

Keep out of reach of children

Other statements can be chosen from the examples listed below, or can be modified as appropriate for the situation:

Do not spray directly onto humans, pets, exposed foods, food utensils or food preparation surfaces.

Do not spray towards the face.

Do not spray into the air.

Remove or cover fish tanks before spraying.

Care should be taken not to spray delicate fabrics or furnishings and plastic surfaces without prior testing.

Total release foggers require the following words (or similar) In addition to the above statements:

FLAMMABLE

Do not spray near flame or fire.

Turn off electrical appliances and extinguish pilot lights in the area being treated.

If the aerosol contains more than 45% flammable contents (with a flashpoint of 61˚C or less) then it also requires the words:

FLAMMABLE

Do not store or use near fire or flame.

If the aerosol contains 45% or less flammable contents (with a flashpoint of 61˚C or less) and is a flammability hazard in the form of either a flammable spray or because it leaves a flammable surface or airborne residue after spraying, then it requires the words:

Do not use near fire or flame.

3.12. ‘Beware’ statement

All aerosol products must include the statement:

BEWARE: Deliberately sniffing or inhaling concentrated spray can be harmful or fatal

This statement must be placed in the ‘Precaution’ section under the general ‘Precaution’ statements.

3.13. Safety directions

Obtain appropriate safety directions from the FAISD Handbook published by the APVMA. Include these directions, preceded by the heading ‘Safety directions’, directly under the ‘Beware’ statement.

3.14. Box

The ‘Precaution’ heading and statements, the ‘Beware’ statement, and any safety directions required must be enclosed in a box outline. The print size and background colour should be designed to draw the user’s attention to this important information.

3.15. First aid instructions

Obtain appropriate first aid statements from the FAISD Handbook published by the APVMA or from the Environmental Protection Authority (EPA). Position the statements below the precautions box, and precede them with the heading 'FIRST AID'.

3.16. Storage and disposal statements

To help the user safely store the product and dispose of the empty container, include an appropriate heading and instructions. Examples of appropriate statements are:

Storage and disposal:
Keep in a cool place out of the sun. Do not puncture or incinerate can, even when empty. Recycle empty cans if a facility is available, or place can in household rubbish.

OR

3.17. Batch number, date of manufacture

The batch number, date of manufacture and, if applicable, the expiry date, must be printed or marked either on a label or directly onto the tinplate. It should comprise numbers, letters, or a combination of numbers and letters. These statements may appear on any part of the label and may be applied as a sticker.

This requirement is mandatory under the Agvet Code Regulations and must be included on all harmonised or Australia-only labels.

3.18. Approval number or registration number

Regulatory authorities in both Australia and New Zealand require an approval or registration number to be included on the label. The following wording must be used for the Australian number:

APVMA Approval No.

New Zealand details may also be included, but these are not checked or approved by the APVMA.

4. General requirements

4.1. Label to be securely attached

Every label used in connection with an aerosol product must be printed on or securely attached to the outside of the container.

4.2. Printing

The label must be printed in compliance with the requirements for label layout, format and legibility.

4.3. Certain statements prohibited

A label cannot include any statement or expression that claims (however stated) that the:

• APVMA or NZ EPA recommends use of the aerosol
• APVMA or NZ EPA guarantees, warrants or assures the safety or efficacy of the aerosol
• aerosol is organic, safe, harmless, non-toxic, non-poisonous, non-injurious or environment-friendly.

4.4. The term ‘natural’

Use of terms such as ‘natural’, ‘naturally derived’ or ‘nature’s way’ must be qualified according to the following:

• The claim must not be misleading; that is, the substance for which the claim is being made must have been formed naturally, and:
  • the term ‘natural’ or similar terms may be used in the distinguishing name of a product if the formulation is 100% natural, or if the term relates specifically to a natural substance contained in the product formulation
  • unless the formulated product is 100% natural, the remaining constituents must be declared in the text of the label as being synthetic.

4.5. Comparatives and superlatives

Terms such as ‘the best’, ‘the most effective’ or ‘superior control’ are not permitted.

4.6. Indefinite terms

Avoid undefined, or generalised terms such as ‘insects’ and ‘bugs’, in the ‘Claims’ or ‘Directions for use’ statements. However, when a product controls all species of a pest type, a collective term such as ‘spiders’ can be used rather than listing multiple types of spiders.

4.7. Additional terms

Some additional examples of expressions or words that are not acceptable include ‘biodegradable’, ‘biodegradable in the environment’, ‘ozone friendly/safe’ and ‘kind to the environment’.

The APVMA can provide advice about the suitability of statements.