In June, the Asociación Española de Aerosoles (Spanish Aerosol Association or AEDA) held its fifth annual Forum & Awards at the Hotel Avenida Palace in Barcelona.
AEDA 2026 Award winners…
Winners included:
Innovation in Packaging Design
Winner
Envases Group for Aluwood
Special Recognition
Lindal Spain for the Luna Actuator
Most Innovative Product
Winner
Coster for Metered BOV
Special Recognition
Aptar for the Clean & Neat Jade
Sustainability
Winner
Valvulas De Precision Española SA for SMART35
Special Recognition
Quimi Romar SL for the Agrado deodorant range
Most Creative Marketing Strategy
Whale Spray for its campaign with Adrian MadMetal, digital content creator and industrial tool and machinery demonstrator from the Canary Islands. SPRAY
The European Union (EU) continues to advance its circular economy objectives with the Packaging & Packaging Waste Regulation (PPWR), one of the most significant packaging reforms in decades. The regulation entered into force on Feb. 11, 2025, replacing the previous Packaging & Packaging Waste Directive (94/62/EC), with most requirements becoming applicable as of Aug. 12, 2026.
The packaging industry is one of the largest users of raw materials in the EU, accounting for approximately 40% of plastic use and 50% of paper consumption, according to the European Chemicals Agency (ECHA). In response, the PPWR aims to reduce packaging waste, improve recyclability, encourage reusable and refillable packaging systems and support the broader transition to a circular economy. A key focus is reducing unnecessary packaging and limiting single-use and overpackaged products.
For manufacturers, importers and brand owners, PPWR introduces several new obligations. Packaging placed on the EU market will need to meet enhanced recyclability requirements and include standardized labeling to facilitate proper sorting and disposal. The PPWR also establishes mandatory minimum recycled plastic content targets for certain categories of plastic packaging, with phased implementation beginning in 2030 and increasing in 2040. In addition, the PPWR includes measures to minimize unnecessary packaging and limit the use of substances of concern.
Recognizing the complexity of the new requirements, the European Commission recently published an official Guidance and a comprehensive frequently asked questions (FAQ) document in response to numerous implementation questions raised by Member States and industry stakeholders. These documents are intended to promote the consistent application of the PPWR throughout Member States by clarifying the interpretation of several provisions within the regulation.
Main Provisions of the PPWR
The PPWR introduces several ambitious targets intended to reduce packaging waste and increase the sustainability of packaging placed on the European market. Member States are expected to reduce packaging waste by 5% by 2030, 10% by 2035 and 15% by 2040, compared with 2018 levels. In addition, all packaging placed on the EU market is expected to be recyclable in an economically viable manner by 2030.
To support these objectives, the regulation establishes reuse targets for selected transport, e-commerce and beverage packaging while prohibiting certain single-use packaging formats beginning Jan.1, 2030. Mandatory deposit-return systems will also be introduced for beverage cans and plastic bottles, accompanied by harmonized packaging labels to help consumers correctly sort packaging waste within the European Union.
PPWR applies broadly to virtually all packaging placed on the EU market, regardless of material type. Its requirements extend throughout the supply chain and cover consumer, commercial, industrial, transport, grouped, e-commerce and reusable packaging.
One of the key design principles introduced by the PPWR is packaging minimization. Packaging must be limited to the minimum weight, volume and empty space necessary to ensure product protection, safety, hygiene, transportation and functionality. Oversized packaging, excessive void space, decorative layers and unnecessary secondary packaging intended primarily for marketing purposes are specifically discouraged.
PPWR promotes the transition from single-use to reusable packaging systems by introducing reuse targets and refill requirements for selected packaging sectors. The regulation establishes provisions for reusable transport and beverage packaging, while also supporting refill systems, including the use of consumer-provided containers in certain takeaway settings. In parallel, it restricts several single-use packaging applications, including selected hotel toiletries, condiment sachets, produce packaging and other convenience packaging formats. These measures are intended to reduce packaging waste and encourage the adoption of more resource-efficient packaging solutions throughout the supply chain.
The regulation also introduces restrictions on substances of concern. Per- and polyfluoroalkyl substances (PFAS) are prohibited in food-contact packaging above specified thresholds. It establishes limits of 25 ppb for any individual PFAS (measured by targeted PFAS analysis, excluding polymeric PFAS), 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS (including polymeric PFAS) where the total fluorine content exceeds 50 mg/kg. Although these provisions are primarily directed at food-contact packaging, they align with the EU’s objective of reducing the use of persistent chemicals in packaging materials.
The PPWR also introduces provisions relating to compostable packaging and establishes clear distinctions between biodegradable, compostable, industrially compostable and home compostable materials. Under the regulation, certain packaging applications may be required to be industrially compostable, subject to final implementing measures and the availability of appropriate collection and treatment infrastructure within Member States. Unlike home composting, which depends on variable environmental conditions, industrial composting occurs under controlled high-temperature and high-humidity conditions designed to facilitate the breakdown of compostable materials. Examples identified by the European Commission include tea bags, coffee pods, produce stickers and certain lightweight food-contact packaging.
Another significant change is the introduction of harmonized packaging labeling requirements across the EU. As implementing acts continue to be adopted, companies can expect additional artwork and labeling obligations, including standardized sorting symbols and other information intended to improve consumer understanding and support recycling initiatives.
Implications for the aerosol industry
Although the PPWR is not specific to aerosol dispensers, many of its requirements apply to the packaging materials and components used throughout the aerosol industry. Manufacturers should assess secondary packaging, plastic components such as caps and actuators, packaging artwork and labeling, and supplier documentation to determine whether changes are needed to meet the regulation’s requirements. While metal aerosol cans already benefit from well-established recycling systems, companies may still need to demonstrate compliance with recyclability, recycled content, labeling and documentation requirements. Working closely with packaging suppliers will help ensure the necessary technical documentation and material information are available to support compliance.
Looking ahead
The EU continues to lead the development of packaging sustainability regulations, and the PPWR is likely to influence future legislation in other markets. Similar initiatives are already emerging around the world, including extended producer responsibility (EPR) programs, recycled content mandates, packaging reduction targets and harmonized recycling labels. While the specific requirements vary by jurisdiction, the overall direction is clear: Packaging is increasingly being regulated not only for its role in protecting products and facilitating distribution, but also for its environmental impact throughout its entire life cycle.
For aerosol manufacturers and brand owners selling internationally, staying informed of these developments will be essential. Companies that proactively review their packaging portfolios and supply chains will be better positioned to adapt as packaging sustainability requirements continue to evolve both within Europe and globally. SPRAY
For an industry built on innovation, convenience and performance, few issues present a greater challenge than balancing product accessibility with public safety. The intentional misuse of legitimate consumer products exemplifies this challenge, existing at the intersection of public health, consumer awareness and responsible product stewardship.
The latest National Survey on Drug Use & Health (NSDUH) from the U.S. Substance Abuse & Mental Health Services Administration (SAMHSA) underscores the importance of continued industry awareness and prevention efforts.i Inhalants represent a broad category that includes adhesives, degreasers, gasoline, gases, nitrites, aerosols and other products manufactured for legitimate purposes. However, some of these products may be intentionally misused to achieve intoxicating effects, often by depriving the brain of oxygen. Although intentional inhalant misuse occurs at significantly lower rates than the use of alcohol, tobacco, marijuana, prescription medications and illicit drugs, attention to this issue remains critically important.
For the aerosol industry, this issue is unfortunately not new. Manufacturers, suppliers, marketers and retailers have long recognized that products designed for specific functions can also be targeted for intentional misuse. As a result, Industry has worked to balance maintaining access to essential products with implementing education and other measures that help reduce opportunities for misuse.
Inhalation abuse can be misunderstood because it does not fit neatly into traditional categories of substance misuse. While some substances are intentionally misused as inhalants because of their addictive properties, many others—including aerosol propellants—do not possess those characteristics. Although these substances may not produce physiological dependence or chemical addiction, repeated intentional misuse can contribute to psychological dependence and compulsive behaviors.
Aerosol products have been part of public discussions surrounding inhalant misuse because of their availability and widespread household presence, but they are only one category of products that may be intentionally misused. HCPA is aware of more than 70 State laws addressing inhalant abuse. More recent laws enacted in Minnesotaii and Oregoniii focus specifically on aerosol dusters, while many others address products such as glues, solvents and nitrous oxide.
For industry stakeholders, the key distinction is that intentional misuse does not diminish the value or necessity of legitimate products. Aerosols support industries ranging from manufacturing and automotive maintenance to electronics, food service, personal care and household applications. The appropriate response is therefore one centered on prevention, education and responsible stewardship.
Readers of SPRAY Technology & Marketing may recall that the U.S. Consumer Product Safety Commission (CPSC) previously considered a rulemaking addressing aerosol dusters associated with inhalation abuse. The issue has now reached Capitol Hill, with two separate pieces of legislation introduced this year.
The Duster Inhalation Prevention Act (S. 5002), introduced by Senator Wyden (D-OR), reflects growing Congressional attention on the intentional misuse of aerosol duster products. As currently drafted, the bill would designate HFC-152a and HFC-134a as hazardous substances under the Federal Hazardous Substances Act (FHSA). It would also prohibit the sale of aerosol products regulated under the FHSA that contain more than 18 mg of one or both of these propellants and authorize the CPSC to designate additional propellants as hazardous.
Separately, the Nitrous Oxide Safety Act (H.R. 7945) was introduced to prohibit the sale of consumer products containing nitrous oxide. The current bill includes important exclusions, including aerosol food products, although some stakeholders continue to advocate for a complete ban.
Regardless of the outcome of these legislative proposals, it is clear that product categories associated with intentional misuse are receiving heightened scrutiny, and industries connected to those products will remain part of the conversation. For the aerosol community, staying informed and engaged is essential. Industry’s message should remain consistent: Aerosol products provide significant benefits across modern life, and those benefits depend on responsible manufacturing, distribution and use.
The challenge is not the existence of these products but rather preventing their intentional misuse while preserving the innovation and value they provide. As new data emerge and legislative discussions continue, collaboration among manufacturers, regulators, retailers, educators and consumers will remain essential to ensuring safety throughout the product lifecycle—from development and distribution to consumer use and disposal.
To stay informed and engage on this critically important issue, please contact me at ngeorges@thehcpa.org. SPRAY
i The 2025 National Survey on Drug Use & Health can be found here.
ii Minn. Stat. § 325F.078
iii Or. Rev. Stat. § 475.376
CARB activity update
Regarding California Air Resources Board (CARB) staff, Moslem Mardi, a manager who works for the Consumer Products Branch Chief, Ravi Ramalingam, is back at work. Josh Berghouse, a CARB staff member who worked on the last Rulemaking and had left the Consumer Products group for another section of CARB, has returned to the Consumer Products group. This will provide CARB staff with more institutional knowledge. As mentioned in my last column, two long-term staff members moved to other sections. Ramalingam, who has been on medical leave since the middle of April, was thought to be coming back in August, but his new timeline is Fall 2026. This is another setback. There is a rumor is that an interim Branch Chief will be assigned to the Consumer Products section soon, so we will need to wait and see.
Currently, Industry is waiting for the Final Results of the latest survey. Also, we are waiting for the draft results of the Personal Fragrance Product (PFP) Assessment. As a reminder, Industry needs to achieve 20 tons per day of emission reductions by 2037. The PFP assessment could lead to more emission reductions needed if the PFP products cannot meet the current volatile organic compound (VOC) limits slated for 2031. Currently, PFP products are to get 5.05 tons per day (TPD) and will likely get some tonnage reductions, but not the full 5.05 TPD. Thus, the tonnage needs will move from 20 TPD to something greater. The rulemaking completion deadline is late 2027, so there is not a significant amount of time to accomplish this goal.
Several associations and industry members met with CARB in August to provide training sessions, including one on Aerosols. A full report of those meetings will be provided in the next issue.
Currently, we have no choice but to wait and see what the results will show. After the results are released, expect CARB staff to work at an expedited pace to make up for past time lapses. If you had products in the past survey, be prepared to be involved with CARB, who will need to set new limits to achieve its VOC emission goals—whether mass-based or the more likely reactivity-based.
Stay tuned, as there will be much more to come.
Other State activity
Oregon, as reported in the last issue, is dropping activity on a Consumer Products Rule.
Maryland is moving forward on updating its Consumer Product regulation from Ozone Transport Commission (OTC) Model Rule IV to OTC Model Rule V. Maryland appears to be moving faster on this than Maine, so look for a draft this Fall.
Maine is planning to move its Consumer Products regulation from OTC Model Rule II to OTC Model Rule IV. The Pine Tree State will likely not present a proposal until 1Q 2027.
Currently, Colorado has OTC Model Rule V as a contingency measure if it does not hit its ozone numbers, which given the current state of activity (extreme heat and wildfires), is likely. Thus, start planning to move to Model Rule V. Colorado is also planning to move to CARB’s current limits; Industry is trying to talk legislators out of this.
New Jersey OTC Model Rule IV became effective August 18, 2026—I hope you made it! SPRAY
In May, the Associação Brasileira de Aerossóis e Saneates Domissanitários (Brazilian Aerosol Association or ABAS) held the second edition of the ABAS Forum & Awards in São Paulo, Brazil. The event brought together 98 professionals from 82 companies and featured 19 speakers from Brazil and abroad.
The program highlighted innovation, sustainability, technical excellence and collaboration across the aerosol value chain and brought together leading figures of the Brazilian and international aerosol industry for two days dedicated to networking and high-level technical content. It featured lectures, panel discussions and debates led by experts addressing the challenges and opportunities shaping the future of the aerosol market.
Speakers included international guest Jaime Verver (Mexico), President of the Latin American Aerosol Federation (FLADA); his presence further strengthened the integration of the Brazilian aerosol industry with key global markets, noted FLADA.
Among the highlights was the presentation of the winning projects from the Mackenzie Hackathon 2026, organized in partnership with Fareva and Beiersdorf. Fifteen engineering students developed solutions to real industry challenges, demonstrating the value of collaboration between companies and universities in preparing the next generation of talent.
The international character of the event was reinforced through messages from global industry leaders, including Jean Blottière, General Delegate of the French Aerosol Committee (CFA); Patrick Heskins, Chief Executive of the British Aerosol Manufacturers’ Association (BAMA); Alain D’haese, Secretary General of the European Aerosol Federation (FEA); and, from the U.S., Nicholas Georges, Senior VP, Scientific & International Affairs at the Household & Commercial Products Association (HCPA). Their remarks highlighted the growing importance of the Brazilian aerosol industry on the global stage and underscored the country’s increasing integration with major international markets, ABAS noted, further adding, “Brazil is currently the world’s fourth-largest aerosol market, making ABAS a key reference for the development and representation of the sector both nationally and internationally.”
ABAS Awards
The awards program achieved a record level of participation, with 29 projects submitted by 11 companies. The entries showcased a high degree of innovation within the Brazilian aerosol industry and, as part of the celebration, attendees also contributed to the creation of the event’s slogan: “It’s ABAS Awards. It’s Innovation. It’s Brazil!”
“The Brazilian aerosol industry, represented by ABAS, is currently experiencing a spectacular moment of global innovation,” said Attila Almásy, Chairman of the ABAS Board.
“I am proud to lead this moment in which we celebrate the prominence of our talents, rewarding those who make a difference in the industry. Today, the excellence of our sector has a name and a brand: ABAS Awards.”
According to Alyne Freitas, then-President of ABAS, the awards demonstrate the industry’s commitment to continuous progress.
“Fostering innovation and sustainability is one of ABAS’ core missions and a responsibility we take seriously as a market with global relevance,” she said.
“The ABAS Awards 2026 made that responsibility visible: with 29 projects and 11 companies recognized, it is a privilege to represent companies that are setting new standards for the industry. Initiatives like these inspire the entire sector, generate business and create a positive impact on society and the environment.” SPRAY
CARB
Consumer Products rulemaking
Since the California Air Resources Board (CARB) webinar on June 2, 2026, some unavoidable obstacles have popped up that will delay the CARB rulemaking process. Earlier this year, two long term staff members for CARB—Dan Garrett and Lucy Negrete—took other positions within the organization and left the Consumer Products sector. While we wish them good luck in their future endeavors, their departure leaves a hole in certain areas of the Consumer Products branch and their knowledge and experience will be missed.
Further, many of you are familiar with the Consumer Products Branch Chief, Ravi Ramalingam, who has spoken at past Western Aerosol Information Bureau (WAIB) events and, just this March, presented on CARB activity in Nashville, TN, at the Aerosol Summit. Unfortunately, Ramalingam has been on medical leave since mid-April. He is expected back soon and we wish him a full recovery. As you can imagine, this has delayed some work. Moslem Mardi, a manager that works under Ramalingam, has been keeping things moving. However, Mardi recently had a personal situation that necessitated him being out until the end of July. With all of these obstacles, it is likely the originally scheduled Consumer Products rulemaking timeline will shift.
Industry had proposed a training session for CARB in mid-July that has now been postponed to mid-August. Hopefully, by late Summer or early Fall, we will be back on track with this rulemaking.
Industry is waiting for the 2023 survey results to be finalized and the best guess is that will be by the end of September. Once the final survey results are released, the categories surveyed can be analyzed to determine if any mass-based volatile organic compound (VOC) reductions or reactivity-based reductions can be accomplished. Remember, just because a category was surveyed does not mean that category will be regulated or re-regulated. Any companies that have products in the surveyed categories should be reviewing formulas for either mass-based or reactivity-based reduction possibilities in order to be ready to engage when the rulemaking begins.
PFP
The Personal Fragrance Products (PFP) industry is waiting for the results of the PFP assessment. These PFP categories were regulated in the last rulemaking with very strict VOC limits.
CARB is reviewing the VOC limits to determine if they need to be adjusted; if the limits are adjusted upward, then more mass-based VOC or reactivity-based VOC reductions will be needed. We are expecting these final assessment results shortly after the above-mentioned survey results.
In the meantime, enjoy the rest of your Summer while we await these results.
Other State activity
Oregon has decided to drop its development of a Consumer Products VOC Regulation. This is great news. Remember, Oregon is the State that is in VOC attainment, but was going to adopt a rule.
Maine is looking into updating its Consumer Products regulation to adopt Ozone Transport Commission (OTC) Model Rule IV. Work will likely start soon and continue through this Fall.
Maryland will be updating its OTC Model Rule IV to OTC Model Rule V. It will be the first State to implement Model Rule V since Colorado adopted OTC Model Rule V for contingency only.
Finally, on Aug. 18, 2026, New Jersey’s new Consumer Products Regulation becomes effective. The rule goes from OTC Model II to OTC Model Rule IV. SPRAY
When ensuring quality control in aerosol product manufacturing, even the simplest of observations can be valuable—such as watching for bubbles.
For decades, the hot water bath test has been one of the industry’s most trusted quality assurance measures. The concept is straightforward: filled aerosol containers pass through a heated water bath, increasing their internal pressure to a prescribed level. If a container has a defect—whether a faulty valve crimp, compromised seam or microscopic pinhole leak—the increased pressure forces product or propellant from the package, creating visible bubbles that indicate a leak.
Despite significant advances in manufacturing technology, the hot water bath remains one of the most widely recognized leak-detection methods in aerosol production. In fact, although the U.S. Dept. of Transportation (DOT) permits alternative testing methods[i], the hot water bath continues to serve as the benchmark against which many leak-detection systems are evaluated.
However, today’s aerosol manufacturing environment bears little resemblance to the industry that existed when the hot water bath test was first introduced.
Historically, aerosol filling lines operated at approximately 40 to 60 containers per minute. At those production rates, it was practical for a trained operator to visually monitor containers as they moved through the water bath and identify leaks based on bubble formation. Today, modern manufacturing lines routinely operate at speeds exceeding 300 containers per minute, with some running even faster depending on product type and package configuration.
This evolution raises an important question: Should leak detection in a modern, high-speed manufacturing environment continue to rely primarily on human observation, or are more advanced technologies better suited to ensuring product quality?
The challenge is not simply one of attention. It’s one of physics and human perception. At high production speeds, containers can create turbulence as they move through the water bath. Air pockets, agitation, splashing and normal movement within the system can generate bubbles unrelated to package leakage. At the same time, very small leaks may produce subtle streams of bubbles that are difficult to distinguish from normal bath activity. Inspectors are expected to differentiate between these conditions in real time while observing hundreds of containers every minute.
As containers move through the bath, their internal pressure increases until reaching the level associated with the required testing temperature of 55°C (131°F), or 50°C (122°F) when the liquid phase does not exceed 95% of the container’s capacity at that temperature. These elevated temperatures and pressures also create safety considerations for employees responsible for removing failed containers from the line.
Although visual observation is widely expected during the hot water bath test, that requirement is not explicitly stated in the Federal regulations governing aerosol products [ii] Rather, the expectation stems from DOT interpretations of the regulation, including Interpretation Response #13-0059, in which DOT states [iii], “The intent of the hot water bath specified in § 173.306(a)(5)(v) is to test the leak proofness of a filled container. Though permanent distortion may be visible during or after the test, leakage must be observed during the test. For this reason, a visual observer must be present for the hot water bath test.”
This interpretation effectively establishes visual observation as a necessary component of the test. While that approach reflected the manufacturing capabilities and production speeds of the past, today’s manufacturing environment presents new opportunities to achieve the same objective through more advanced technologies.
Modern leak-detection systems have advanced significantly and can identify leaks with levels of consistency and sensitivity that often exceed human capability. Unlike human inspectors, automated systems do not experience fatigue, distraction or reduced effectiveness during extended production runs. They can continuously inspect every container, record inspection data and provide traceable documentation that supports both quality assurance and regulatory compliance.
Recognizing these advancements, members of the Household & Commercial Products Association’s (HCPA) Aerosol Products Division formed a task force to explore opportunities for modernizing leak-detection practices while maintaining the industry’s longstanding commitment to safety. The task force is evaluating alternative leak-detection technologies and documenting their performance relative to traditional visual observation. Through data collection, technical analysis and industry education, the group aims to demonstrate that certain automated methods can provide leak-detection performance that is equivalent to, or exceeds, that of a visual observer monitoring a hot water bath test.
As this work continues, the industry has an opportunity to engage regulators in a constructive dialogue about modernizing leak-detection requirements while preserving the rigorous safety standards that have long defined aerosol product manufacturing. The future of leak detection should not be measured by how closely it resembles past practices, but by how effectively it identifies defects, protects consumers and workers, and ensures product integrity in an increasingly advanced manufacturing landscape.
After all, ensuring aerosol product integrity is too important to rely solely on methods developed for a manufacturing landscape that has changed dramatically over time. The aerosol industry has never been afraid to innovate, and leak detection should be no exception. As manufacturing technology continues to evolve, so too should the tools and practices used to ensure every aerosol product meets the highest standards of safety and quality.
To learn more about the Leak Detection Task Force or to get involved, please contact me at ngeorges@thehcpa.org. SPRAY
i For more information on water bath alternatives in the U.S., CLICK
ii For federal regulations concerning the hot water bath test, see 49 CFR §
iii link
Hello, everyone. Corrosion is everywhere and it’s expensive. Indeed, the estimated cost of worldwide corrosion services—testing, consulting, inhibitor/coating/laminated films for control and prevention—is expected to hit $3.48 trillion by the end of 2026.
The spray packaging corrosion risk is always greater than zero and as high as 62%, particularly when there is no corrosion data for a new formula or derivatives of current formulas (line extensions).
Two types of corrosion tests are available for spray packaging:
1. Traditional long-term storage stability tests
2. Electrochemical corrosion tests
Figure 1 depicts the corrosion risks associated with each of these tests as a function of test length.
The storage test curve in Figure 1 is from one-year-old package examinations for pitting corrosion of approximately 7,500 aluminum, tin-plated steel and tin-free steel aerosol containers (approximately 750 to 1,000+ storage tests). The electrochemical test curve in Figure 1 was generated from over 1,500 direct comparisons between predictions from Aristartec corrosion test results and actual package corrosion.
Notice in Figure 1 that risk decreases as the test length increases. Thus, results from a short storage test typically have a higher risk than results from a long storage test. In other words, storage test risk decreases as the amount of corrosion data increases with increasing test time. This is why I recommend conducting storage tests for at least one year before making a “Go/No-go” decision to commercialize new products or derivative products.
Figure 1 also illustrates that the risk for a properly-designed:
• Storage test typically decreases from 62% to around 7% after one year of testing
• Electrochemical test typically decreases from 62% to < 1% within 90 days of testing
In other words, an electrochemical test can be completed in a significantly shorter time than a storage test with a corresponding lower risk.
Why corrosion risk is always a concern
Small changes to a formula’s chemical composition can cause very large changes in corrosion behavior. For example, changing to a new fragrance or a new surfactant in a non-corrosive formula sometimes results in a corrosive new derivative product.
Corrosion can unexpectedly appear with changes in the concentrations of formula ingredients, either by design or from manufacturing batch-to-batch variations. For example, an inhibitor can lose its effectiveness when its concentration is either above or below the effective concentration range. Also, contaminants, such as water in anhydrous formulas, are a common cause for spray package corrosion.
Substituting formula ingredients from alternate suppliers could also cause unexpected corrosion in spray packaging.
Variability in formula ingredients, formula ingredient concentrations, package components and materials-of-construction also causes random corrosion in some instances.
Major elements of control & prevention
Figure 2 provides a diagram for the major elements of a corrosion control and prevention program. Corrosion testing is the linchpin of any comprehensive corrosion control and prevention program; it determines formula compatibility with metal and plastic package components, package metals and coatings.
Figure 2 implies that one doesn’t have to abandon a corrosive formula. In most instances, a corrosion inhibitor can be developed to transform a corrosive formula to a non-corrosive one. However, corrosion inhibitors typically have an effective concentration range, above or below which the inhibitor could actually cause corrosion. Coatings in some instances can also inhibit or prevent corrosion.
Corporate knowledge and an experience database can also help avoid formula-package combinations and formula ingredients that have a high probability of causing spray package corrosion. Such a database can also help reduce the number and length of corrosion tests in some situations.
“Knowledge + Experience” are shown in Figure 2 with a plus sign (+) between them to emphasize that they are interconnected. Knowledge without practical experience, and experience without theoretical frameworks, are incomplete and will not result in useful, predictive professional practice. In other words, experience and knowledge work together to complete a comprehensive corrosion control and prevention program.
Corrosion control and prevention are typically not part of most corporate business plans or mission statements, but product efficacy, quality and safety are! Ignoring corrosion risk could lead to a major disruption of business plans with a corresponding loss of income; re-deployment of resources to determine the cause and find a solution may also delay other projects.
Ignoring risk can also result in either an expensive product recall or litigation with subsequent potential loss of future sales when customers/consumers lose confidence in products; the liability for product recalls with litigation can range from $43 million–$196 million. A comprehensive corrosion control and prevention program also helps prevent the loss of productivity and expense that accompany both in-development and in-market product failures. Consequently, corrosion testing is significantly cheaper than both in-development and in-market corrosion failures.
It bears repeating: corrosion prevention and control should be a continuous process and not a one-time event.
Thanks for your interest and I’ll see you in November. Contact me at 608-831-2076; rustdr@pairodocspro.com or from our two websites: pairodocspro.com and aristartec.com. SPRAY
In May, the Household & Commercial Products Association (HCPA) held its Mid-Year Meeting at a new venue—The Capital Hilton in Washington, D.C.
During the General Session, the HCPA thanked Stephen J. Caldeira and his nearly 10 years of outstanding leadership as he prepares to conclude his tenure as President & CEO in July 2026. The Association noted that, since joining HCPA in 2017, Caldeira has guided it through a period of growth and innovation. Under his leadership, HCPA strengthened its voice in Washington, advanced key policy priorities and deepened its value to members navigating an increasingly complex regulatory landscape.
Among his many contributions, Caldeira spearheaded the rebrand of the Consumer Specialty Products Association (CSPA) to HCPA. He is widely recognized as one of Washington’s most effective and trusted advocates, consistently recognized by The Hill as a Top Lobbyist and honored with CEO Update’s Trade Association CEO of the Year Award in 2022.
The HCPA said in a statement, “Those who have worked with [Caldeira] know him not only for his policy expertise, but also for his kindness, integrity and unique ability to bring people together across different perspectives. Beyond his professional impact, Steve has been a generous and engaged leader in the broader community, contributing his time, expertise and leadership to numerous boards and advisory groups.
“While we are saddened to see this chapter come to a close, we are deeply grateful for the lasting impact Steve has had on HCPA, the industry we serve and the many people who have had the privilege of working alongside him.”
Aerosol Products Division
During the Aerosol Products Division Program, the A Can-Do Conversation: Aerosol Recycling & Sustainability panel featured Sami Ki, HCPA Senior Manager, Sustainability & Product Stewardship; Manon Pascal, Regulatory Affairs Manager, Lindal North America; and Allison Lim, Innovation Analyst, RTI International.
Ki presented an Aerosol Recycling Initiative (ARI) Update. Highlights from Phase 1 include the research of the environmental and economic impact of improved aerosol recycling; analysis of the state of current recycling-related labeling on aerosols; can testing to assess the amount of residual content remaining in aerosols; consumer survey to understand current awareness and the publishing of a White Paper. Findings of the White Paper showed the benefits of a 50% recycling rate of aerosols:
• $39M+ in material revenues
• $43M+ in direct wages paid
• $8.5M+ landfill tipping fees saved
• 13k tons of aluminum recycled content
• 137k tons of steel recycled content
• 366,622 MTCO2e GHG reductions
The next phase progressed toward targets, and the highlights of Phase 2 include forming the ARI Labeling Task Force to develop a guide with message options to meet the labeling goal; engaging materials recovery facilities (MRFs), municipalities and retailers to offer aerosol recycling access; and advocating for inclusion of aerosol cans on Statewide “recyclable” lists.
ARI collaborated with RTI Innovation Advisors to produce and publish the “MRF Playbook”; partnered with Circular Action Alliance (CAA) in the Portland, OR, Metro area to create consumer educational messaging; conducted baseline residue testing from cans collected at Far West MRF in Portland; and worked with Kessler Consulting to engage the city of Sarasota, FL, and Waste Pro towards explicit acceptance of aerosols.
The ARI, CAA and metro local governments developed consumer education messaging—How to Recycle Empty Aerosol Cans—with the goal of improving acceptance of empty aerosol products in the Portland, OR, Metro area. The marketing campaign was launched mainly via social media, but also via mailers.
Residue testing was conducted to establish a baseline. Samples were sourced from Far West MRF in July 2025, with two totes containing a total of 2,385 aerosol containers collected (1,884 steel aerosol containers [78.99%], 492 aluminum aerosol containers [20.63%] and nine plastic aerosol containers (0.38%). Sorting and testing was completed in September 2025 at Recycle Aerosol in Tennessee.
The total aggregate residue level was 10.7%; by comparison, 2023 testing had an average residue level of 11.5% overall.
On the horizon, the second round of can testing will be done at Far West and an outside MRF to determine the impact of the marketing campaign on consumer behavior. An operations assessment and residue testing will be conducted at a Waste Pro MRF. An aerosol recycling education messaging toolkit will be created and the MRF Playbook will be leveraged to engage MRFs on explicit acceptance of aerosols. A guidance document for design of aerosol product for recyclability will be developed.
Pascal presented How Packaging & Packaging Waste Regulation (PPWR) is reshaping aerosol sustainability in the EU. PPWR addresses packaging lifecycle and it’s potentially negative impacts on the environment and human health; waste prevention to harmonize national measures and improve the internal market; and more sustainable packaging solutions. This will impact aerosol design, such as the substances in packaging and minimum recycled content. Regulatory constraints will affect labeling and extended producer responsibility (EPR), as well as packaging minimization. Uncertainty remains concerning recyclability grades. EPR changes under PPWR will include clearer regulation, a less fragmented national EPR system, more uniform fee structures, a broader scope (such as e-commerce) and a design-driven approach.
Lim presented Lessons from Aerosol Can Recycling. RTI International partnered with the ARI, led by the Can Manufacturers Institute (CMI) and the HCPA, to identify and understand the incentives and barriers influencing MRFs’ acceptance of aerosol cans. RTI interviewed 14 MRFs across 11 States to capture a broad view of aerosol recycling practices and barriers. Six explicitly accept empty aerosol cans; four accept them but do not explicitly state that; and four do not accept empty aerosol cans.
Three key risks to accepting aerosol cans were identified based on interviews with MRFs across the U.S.:
1. Safety: Aerosol cans, particularly non-empty cans, can cause fires/explosions that put workers at risk and can damage equipment.
2. Downstream contamination: Aerosol cans may be viewed as contaminants in other metal streams, creating challenges for downstream processors and buyers.
3. Lack of end market: There may not be readily accessible buyers for bales containing aerosol cans, limiting the economic viability of acceptance.
Lim noted that all three risks are real but that all three are manageable with the right procedures. Regarding safety, aerosol fires are proportionally rare, compared to lithium ion batteries (40%) and propane cylinders (20%). Non-empty cans are the primary hazard, but front-end sorting stations and education can intercept most risk. Prevention and mitigation frameworks make acceptance operationally safer, while resident education on “empty means empty” can reduce non-empty cans at the source.
Contamination risk is driven by non-empty cans and aerosols ending up in the wrong bale and both are preventable. Clear acceptance criteria communicated upstream to municipalities and residents is the highest-leverage intervention. Equipment upgrades and quality control at sorting stations can reduce downstream contamination impact.
Concerning lack of end market, brokers and scrap managers readily accept steel bales without price penalties or rejections, said Lim. Sheet mills reject aluminum aerosols, but secondary processors provide viable pathways. The end market concern is often a perception gap—MRFs are avoiding aerosols based on assumptions that buyers don’t share and proactive buyer conversations before acceptance decisions are a key first step.
Empty aerosol cans can be recycled, noted Lim. Facilities doing this well aren’t exceptional—they’re informed. The Yes, We Can! playbook provides the operational toolkit to start closing the information gap.
Cindy Newberg, Chemicals, Coatings & Products Division Director, Office of Air & Radiation, U.S. Environmental Protection Agency (EPA), presented Overview for Aerosols. The American Innovation & Manufacturing (AIM) Act authorizes the EPA to regulate hydrofluorocarbons (HFCs) in three main ways: phase down HFC production and consumption through an allowance allocation and trading program; manage use and reuse of HFCs by maximizing reclamation and minimizing releases from equipment; and transition sectors to next-generation technologies through restrictions on use of HFCs. Newburg offered an extensive amount of technology transition resources and encouraged those who had questions or who wanted to join the Technology Transitions contact list, to send an email to: HFCTransitions@epa.gov.
Brian Houston, GM, Foam, Aerosol & Solvents, Solstice Advanced Materials, presented U.S. Aerosol Policy Landscape. PFAS (perfluoroalkyl and polyfluoroalkyl substances) policy in U.S. States remains an active discussion. The aerosol sector is impacted by PFAS, HFC and volatile organic compound (VOC) regulations. However, there are innovation opportunities via medical and Significant New Alternatives Policy Program (SNAP) exemptions.
Product classes in Medical Exemptions include over-the-counter drug products, such as sunscreen, acne cream or dandruff shampoo, as well as medical devices, such as topical anesthetic spray. Therefore, innovation can move forward with topical pain relief sprays, for example.
Steven Andrews, Acting Senior Regular Regulations Officer, U.S. Dept. of Transportation (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA), presented New & Upcoming Initiatives. Recent key Executive Orders include Unleashing Prosperity Through Deregulation (EO 14192) and Unleashing American Energy (EO 14154). In April 2025, DOT issued a Request for Information, seeking input on regulations or guidance to repeal or modify to cut costs and improve efficiency while maintaining safety. In June 2025, PHMSA issued Advance Notice of Proposed Rulemaking (ANPRM) (HM-265B) seeking feedback on opportunities to improve Hazardous Materials Regulations (HMR).
On July 1, 2025, PHMSA published 17 Notice of Proposed Rulemakings (NPRMs) in the Federal Register, seeking to eliminate outdated, unnecessary and overly burdensome regulatory requirements within the HMR. The vast majority of comments received were supportive, with some helpful feedback, as well. The Final Rules were projected to be published in Spring 2026, but were not yet available.
Other open rulemaking actions include HM-268A—Aerosol Definition Harmonization; HM-266—Modernizing Regulations to Facilitate Transportation of Hazmat Using Highly Automated Transportation Systems; and HM-267— Modernizing Regulations to Facilitate Transportation of Spacecraft and Space Related Hazmat.
In 2025, PHMSA implemented the 30-day pending interpretation process to modernize how it provides regulatory guidance. The change was driven by two primary goals: transparency and stakeholder engagement. PHMSA conducts a preliminary review of an incoming Letter of Intent[CH1.1] request, which is posted to a public “Pending” page on the PHMSA website (separated into Pipeline and Hazmat sections). Stakeholders have 30 days to submit comments; PHMSA reviews the comments and then issues a final, written interpretation or denies the request.
Don Burger, Director of the Special Permits Program, PHMSA, presented Intersections: Special Permits & Aerosols. A special permit is a document that sets forth alternative requirements, or variances, to the HMR requirements. It is, in effect, a permission slip to perform an action that would not otherwise be allowed under the terms of the HMR. An applicant must demonstrate that the proposed alternative achieve a level of safety, at least equal to that required by the regulation. If no regulation exists, the proposal must be consistent with the public interest.
There are many instances where special permits have been issued for use by the aerosol industry, for example, thin-walled aerosol cans; alternative to hot water bath tests; alternative pressure relief systems; pure gases in aerosol cans; higher pressure gases in aerosol cans; and plastic aerosol cans. Special permits have introduced innovation into the aerosol industry, Burger emphasized.
Sometimes regulation and innovation appear to be separate from one another but special permits exist at the intersection of innovation and regulation. They have introduced innovation into the aerosol industry and will continue to do so into the future, he concluded.
In the April 2026 edition of the BAMA Bulletin, I took the opportunity to share some innovative ideas that university students brought to BAMA back in 2005. For presentation at the BAMA Innovation Day this year, we invited a group of students from Leeds Beckett Business School to consider the task to “explore the innovation landscape of the aerosol sector to identify, justify and propose an innovative idea to enhance competitiveness, resilience and sustainability.”
Modular Aerosol Architecture
We ended up with five fantastic presentations from six students. Aneesh Babu and Himanshu Nikam started us off with a discussion on Modular Aerosol Architecture, which they called CRRH. Their plan was to produce new components that would fit onto existing aerosol containers, but utilizing a reusable spray head, a lock system to attach the spray head to the container and a reusable barrier chamber that contains the product. The concept shifted aerosols from a linear “make, use, dispose” model to one in which companies inspect and refurbish components rather than making new ones each time.
SprayLink, a “Forever Can” & ZPAA
Olamide Dairo had a similar refillable concept, but with Project Aura—a “Forever Can” refilled with pods of product via a docking station. He then took this concept further, suggesting that companies could develop subscription models to increase revenue and reduce investment costs for both manufacturers and consumers.
The third presentation was from Senyo Agbleze, who challenged the aerosol industry to develop Zero Pressure Aerosol Architecture (ZPAA). This was also built around a refill model, but used a mechanical atomization system to create the spray. His concept was designed to be used across different categories, including traditional areas CRRH Modular Aerosol Architecture Project Aura where the aerosol has many advantages, such as shaving preparations and medical and pharmaceutical devices.
Thi Hong Nhung Le then took the audience through the idea for a mechanical system called SprayLink, which had a reusable “dry” engine to create the spray, alongside a “wet-energy pod” that contained the product and provided the energy for Zero Pressure Aerosol Architecture the system.
New tech for a closed loop approach
Our final presentation was by Vedang Sen, who examined how we might create a closed-loop approach to recover the aerosol package. This involved using QR codes and blockchain technology to track products through the manufacturing, use and recovery processes before they are reused or remanufactured into new aerosol dispensers.
Winners
Having heard the “elevator pitch” from each of the students, the audience was invited to vote for a winner.
In third place was Vedang Sen, for his closed-loop aerosol packaging system, taking home an iPad mini. Second was Thi Hong Nhung Le, for SprayLink, who won an iPad. The very deserving winner was Senyo Ableze for his ZPAA concept; he left the conference with a MacBook Neo. All of the presentations can be found on the BAMA website by navigating to the Innovation Day page.
All of the attendees were mightily impressed by the quality of the work the students produced and their confidence as they stood up in front of an audience of 180 people to make their pitch. We at BAMA would like to thank all the students who took part, as well as Adekunle Oke, Dr. David Chikwere and Olga Munroe of Leeds Beckett University for helping to make this happen. SPRAY
