Guides / US diffuser and spray labels

US reed diffuser and room spray label requirements

Published 28 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.

In the United States a reed diffuser or room spray carries no CLP label and no pictograms. Two sets of rules decide what goes on it. Every package needs three things from the FTC's packaging rules: what the product is, your name and place of business, and the net contents in fluid ounces and millilitres. When the finished liquid is flammable, combustible, toxic, an irritant or a strong sensitizer, the Federal Hazardous Substances Act (FHSA) adds a warning: a signal word, statements of hazard, the components behind them, precautions, first aid and "Keep out of the reach of children", in letters at least as tall as your bottle's front panel calls for. Some liquids also need a child-resistant closure.

Step one: is your finished liquid a hazardous substance?

The FHSA's warning is for a product that is toxic, corrosive, an irritant, a strong sensitizer, flammable or combustible, or that generates pressure, and that may cause substantial injury or illness in customary or reasonably foreseeable handling or use, including a child swallowing it (15 U.S.C. 1261(f)). CPSC advises judging the finished product that consumers will use, not its ingredients one by one, and it warns that a safety data sheet's GHS classification can differ from what the FHSA requires. Its own example is flammability: GHS calls a liquid flammable up to a flash point of 199.4 °F (93 °C), while the FHSA draws its lines at 20, 100 and 150 °F.

A diffuser or spray that is none of these needs no warning at all, only the package basics further down this page.

The flash point sets the flammability words

The bands are those of 16 CFR 1500.3(c)(6), measured by the closed-cup method of 16 CFR 1500.43a on the finished liquid; the flash point of the fragrance oil or the base alone is a different number. One exception matters for sprays: a water solution with 24 % or less water-miscible alcohols by volume is not treated as flammable or combustible if it presents no significant flammability hazard when consumers use it (1500.3(c)(6)(ii)(B) and (iii)(B)). It does not reach an extremely flammable liquid.

Other hazards, and the substances with set wording

Toxic, irritant and strong sensitizer each have a definition and a test in 16 CFR 1500.3, and your data for the finished liquid decides them. A few substances bring wording the regulation prescribes when a product holds them at or above a set level (16 CFR 1500.14):

Two of the strong sensitizers CPSC lists can turn up in these products (16 CFR 1500.13): a product with oil of bergamot at 2 percent or more, or formaldehyde at 1 percent or more, is a strong sensitizer, a hazard its label has to state. Oil of bergamot is a common fragrance material, so check your blend's share of it.

What the warning must say

For a hazardous substance, the label states, in English (15 U.S.C. 1261(p)):

1. The signal word: DANGER for extremely flammable, corrosive or highly toxic products; WARNING or CAUTION for all other hazardous substances.
2. A statement of each principal hazard, such as FLAMMABLE, COMBUSTIBLE or VAPOR HARMFUL, in capital letters (16 CFR 1500.121(c)(4)).
3. The name of each component that contributes substantially to the hazard, by its common or usual name, or its chemical name. A product whose only hazard is being flammable or extremely flammable may leave it out (16 CFR 1500.83(a)(1)); combustible is not in that exemption.
4. Precautionary measures: what to do or avoid.
5. First-aid instructions, when necessary or appropriate.
6. Handling and storage instructions for a package that needs special care.
7. "Keep out of the reach of children" or its practical equivalent.
8. The word POISON for a highly toxic substance, and where 16 CFR 1500.14 requires it.
9. The name and place of business of the manufacturer, packer, distributor or seller.

With more than one hazard the label states each one, with the precautions and first aid for each; parallel information may be combined when the combined statement still says everything needed for each hazard (16 CFR 1500.127). The wording of the precautions and first aid is yours: take it from your supplier's documents and your own data.

The label above comes from the tool with the bottle and flash point shown in the US reed diffuser and room spray examples, which also show a diffuser with a petroleum-distillate base on front and back labels, an alcohol room spray and a linen spray that needs no warning.

Where it goes, and how big

• On the front, the signal word, the statements of hazard and, when cautions are elsewhere, "Read carefully other cautions on the ___ panel" are blocked together in a square or rectangular area, set apart from other printing by a border line or a space (16 CFR 1500.121(b)(2)(ii)).
• The other cautions go together on one panel; the name and place of business may stand apart (1500.121(b)(3)).
• In capitals for the signal word and the statements of hazard, all statements in the same size and style, and no capital more than three times as tall as it is wide, which rules out tall condensed lettering (1500.121(c)(3) to (5)).
• On any box or wrapping used in retail display too, unless the bottle's warning can be read clearly through it (1500.121(b)(4)).

The minimum letter heights are for capital letters and depend on the area of the front panel: height times width for a flat side, or 40 % of the height times the circumference for a round bottle, with shoulders and neck left out (16 CFR 1500.121(c)(1)). Table I of 1500.121(c)(2):

The example's round bottle, 3.5 inches tall and 2.2 inches across, has a front panel of 9.7 square inches, so its capitals must be at least 3/32 inch for the signal word, 1/16 inch for the statements of hazard and 1/16 inch for the other cautions. Cautions on another panel are sized by that panel's area, and the "Read carefully" line on the front must be at least the size Table I sets for them (1500.121(c)(2)(iii)).

What every package needs, warning or not

A diffuser or spray is a consumer commodity under the Fair Packaging and Labeling Act, labelled by the FTC's rules in 16 CFR Part 500:

1. What it is, on the front, as a principal feature: its common or usual name, such as "Reed Diffuser" or "Room Spray" (500.4).
2. Your name and place of business: street address, city, state and ZIP code, with "Manufactured for" or "Distributed by" when someone else made it. The street address may be left off if it is listed in a readily accessible, widely published and publicly available resource such as a directory or a website (500.5).
3. The net contents, as fluid measure for a liquid, in both US fluid ounces and millilitres, for example "8 fl oz (236 mL)" (500.7, 500.8(b)). The conversion uses NIST Handbook 133 (500.19), and the regulation's own examples cut the figure rather than round it up: 8 fl oz is 236.59 mL, written "236 mL".

The net contents is a separate item on the front, in the bottom 30 % unless the front is 5 square inches or smaller, in easily legible bold type or print that stands out from the rest (500.6(b), 500.20), with a minimum letter height set by the same panel area (500.21(b)):

When the bottle needs a child-resistant closure

The Poison Prevention Packaging Act rules list the household products that must be sold in child-resistant packaging (16 CFR 1700.14(a)). The entries that can reach a diffuser or spray:

• Hydrocarbons: a liquid that is an FHSA hazardous substance, is not an emulsion, holds 10 % or more hydrocarbons by weight and is thinner than 100 SUS at 100 °F. Hydrocarbons are substances of carbon and hydrogen only, added together, so fragrance materials such as limonene count toward the 10 %. A spray is excepted when the only way to the liquid is a pump or trigger that is child-resistant or permanently attached (1700.14(a)(31)).
• Methyl salicylate: a liquid with more than 5 % by weight, other than in a pressurized spray container (1700.14(a)(3)).
• Turpentine at 10 % or more by weight, methanol at 4 % or more, and ethylene glycol at 10 % or more (1700.14(a)(6), (8) and (11)).

Child-resistant packaging has to meet the standards of 16 CFR 1700.15. It is a feature of the bottle and its closure, bought in rather than printed, so settle it before you design the label.

If you also sell in Europe or the UK

The same diffuser needs a different label there: CLP pictograms, H and P statements and, in the EU and Northern Ireland, a UFI. The CLP page for diffusers and room sprays covers it, and the home-fragrance tool makes both from one design.

Common questions