Interpretation Response #26-0027
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Bona
Individual Name: Sona Pithadia
Location State: NC Country: US
View the Interpretation Document
Response text:
April 2, 2026
Sona Pithadia
Regulatory & Sustainability Manager
Bona
4275 Corporate Drive
Monroe, NC, 28110
Reference No. 26-0027
Dear Ms. Pithadia:
This letter is in response to your February 20, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of pressurized hazardous materials. Specifically, you ask about the classification of a product that: 1) is transported in a pressurized container (i.e., aerosol or bag-on-valve system); 2) is expelled by a propellant that may be a hydrocarbon, or a non-flammable compressed gas (nitrogen/air/CO₂) and; 3) contains a liquid product that may or may not contain flammable components.
We have paraphrased and answered your questions as follows:
Q1. Does the presence of a pressurized container, or labeling (of a container) with markings such as "contents under pressure" automatically classify a product as a flammable aerosol?
A1. No. "Aerosol" is defined in 49 CFR § 171.8. Classification of a product as a flammable aerosol is based on the properties of the materials in the packaging (i.e., the pressurized container). The criteria to classify a product as a flammable aerosol is specified in § 173.115(l).
Q2. Is flammability determined by the packaging format (e.g., pressurized container) or by the finished product formulation and applicable testing criteria (e.g., flash point, ignition/flammability testing)?
A2. Classification is determined based on the properties of the contents of packaging (see answer A1).
Q3. Can a pressurized liquid that is expelled by a non-flammable compressed gas propellant be classified as non-flammable depending on the final formulation and test results?
A3. Yes, depending on the flammability of both the pressurized liquid and the compressed gas. See answer A1.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
171.8 173.115(l)