What AerD is and why it matters
The Aerosol Dispensers Directive (AerD) — formally Council Directive 75/324/EEC on the approximation of the laws of the Member States relating to aerosol dispensers — is the EU’s harmonised law for the construction, filling, testing and labelling of aerosol dispensers. If you fill, manufacture, import or sell pressurised spray cans into the European market, this is the rule that governs how those dispensers must be built and marked. It covers familiar everyday products such as deodorants, hair sprays, spray paints, cleaning sprays, lubricants and insecticides, and it sets the technical baseline that lets a compliant aerosol move freely across the EU.
AerD matters because aerosol dispensers combine a pressurised container with — very often — a flammable propellant and contents. The Directive exists to manage that combined mechanical and fire hazard through harmonised rules on capacity, internal pressure, container strength, leak and burst testing, and clear hazard information for the user. Because it is a directive, it is transposed into each Member State’s national law, but the technical annex it sets out is common across the Union, so a dispenser built and marked to AerD can be placed on the market in every Member State.
📄 Official text: Council Directive 75/324/EEC on aerosol dispensers — on EUR-Lex →
Who AerD applies to
AerD is built around the actor who fills and markets the dispenser, but the duties reach across the chain that brings an aerosol to the consumer:
- Fillers and manufacturers — the party who fills the aerosol dispenser and is responsible for its construction and testing carries the core obligations. They must ensure the dispenser meets the Directive’s construction, pressure and capacity rules, undergoes the required testing, and bears the correct markings before it is placed on the market.
- The person responsible for marketing — AerD requires the name or trade name and address (or mark) of the person responsible for marketing the aerosol dispenser to appear on the dispenser. This identifies the operator accountable for the product within the EU.
- Importers — businesses bringing aerosol dispensers into the Union must ensure the products they place on the market satisfy AerD’s requirements and carry the mandatory particulars, including the conformity mark.
- Distributors and retailers — those further down the chain handle and sell the dispensers and should ensure the products they supply carry the required markings and hazard information.
The Directive applies to aerosol dispensers — non-reusable containers made of metal, glass or plastic, containing a gas compressed, liquefied or dissolved under pressure, fitted with a release device allowing the contents to be ejected as a spray, foam, paste, powder or in liquid state.
Key dates and timeline
- 1975 — Council Directive 75/324/EEC was adopted, harmonising national rules on aerosol dispensers so that compliant products could circulate freely across the common market.
- Subsequent amendments — AerD has been amended several times to keep pace with technical and safety developments. A notable change introduced an explicit flammability classification for aerosols and the corresponding hazard labelling, and later amendments adjusted definitions, capacity and pressure provisions and the classification and labelling rules to align with wider EU chemicals law.
- Ongoing transposition — because AerD is a directive, its requirements are given effect through national legislation in each Member State, and amendments are transposed as they are adopted.
Core requirements
Construction, capacity and pressure
At the heart of AerD are the rules on how an aerosol dispenser must be built and filled. The Directive sets requirements for the construction and strength of the container so that it can safely withstand the internal pressure it will be subject to in normal and reasonably foreseeable conditions, including elevated temperatures. It lays down limits on the capacity of dispensers — differing by container material (metal, glass or plastic) — and on the internal pressure and filling ratio, so that the relationship between the volume of liquid filled and the pressure generated stays within safe bounds. These provisions are designed to prevent the container from bursting and to ensure the release device functions correctly.
Testing
AerD requires aerosol dispensers to be tested before being placed on the market. The Directive’s annex describes the testing regime the filler must apply, including hydraulic pressure testing of containers and final testing of filled dispensers — typically immersion in a hot water bath or an equivalent method — to verify that dispensers do not leak or deform and can withstand the pressures and temperatures they may encounter. The filler is responsible for ensuring the testing methods used demonstrate conformity with the Directive’s safety requirements.
Flammability classification and hazard labelling
Aerosols frequently contain flammable propellants or contents, so AerD provides for the flammability classification of aerosol dispensers and the corresponding hazard labelling. Depending on the flammability of the contents, dispensers are classified and must carry the appropriate hazard warnings and safety information. In addition, every aerosol dispenser must bear certain standard cautionary statements — including warnings that it is a pressurised container, that it must be protected from sunlight and not exposed to temperatures above a stated level, that it must not be pierced or burned even after use, and that it must be kept away from sources of ignition — together with any warnings appropriate to the specific product. This labelling ensures users handle and dispose of the pressurised, potentially flammable container safely.
The conformity mark — inverted epsilon “3”
A central feature of AerD is the conformity mark: the symbol resembling an inverted (reversed) epsilon, sometimes described as the “3” mark. A filler who has verified that an aerosol dispenser conforms to the Directive’s requirements affixes this mark to the dispenser. The mark signifies that the product satisfies AerD and may be placed on the market and circulate freely throughout the EU. It functions much like the free-movement guarantee of other harmonised product rules: the mark is the visible declaration that the construction, testing and labelling obligations have been met.
Mandatory particulars on the dispenser
AerD requires a defined set of mandatory particulars to be marked legibly and indelibly on each aerosol dispenser (or, where size prevents it, on a label attached to it). These include the conformity mark, the name and address or mark of the person responsible for marketing, a coding element identifying the filling batch (for traceability), the net contents, and the cautionary and hazard statements required by the flammability classification. Together these particulars allow the product to be traced, identify who is accountable for it, and tell the user how to handle it safely.
Obligations by role
- Fillers / manufacturers — ensure construction, capacity, pressure and filling-ratio rules are met, carry out the required testing, classify the contents for flammability, apply the conformity mark and mandatory particulars.
- Persons responsible for marketing — ensure their name/trade name and address appear on the dispenser and that the product placed on the market is compliant.
- Importers — verify that imported aerosol dispensers meet AerD and carry the conformity mark and mandatory particulars.
- Distributors and retailers — handle and supply only dispensers bearing the required markings and hazard information.
Enforcement
AerD is transposed into national law, and each Member State designates the competent authority responsible for market surveillance of aerosol dispensers. In Denmark, the Danish Safety Technology Authority (Sikkerhedsstyrelsen) is the competent authority for product safety matters of this kind. Authorities can check that dispensers carry the conformity mark and mandatory particulars, that the construction, pressure and capacity rules are respected, and that the flammability classification and hazard labelling are correct.
Member States must in principle allow aerosol dispensers bearing the conformity mark to be placed on the market, but they retain safeguard powers: if a compliant-marked dispenser is nonetheless found to endanger safety, an authority can act to restrict it and notify the Commission. Consequences for non-compliance are set at national level and can include orders to stop sales, withdrawals from the market and penalties.
Getting compliant
- Confirm your product is an aerosol dispenser within AerD’s scope and identify the container material.
- Apply the construction, capacity, internal-pressure and filling-ratio rules for that material.
- Carry out the required pressure and final testing on containers and filled dispensers.
- Classify the contents for flammability and select the corresponding hazard labelling.
- Affix the conformity mark (inverted epsilon “3”) once conformity is verified.
- Mark all mandatory particulars legibly and indelibly: marketing-responsible person, batch code, net contents, and cautionary/hazard statements.
- Keep records demonstrating that the construction and testing requirements have been met.
Related guides
How Conphora helps
Conphora monitors AerD and maps your aerosol products against its requirements, flagging gaps in construction, pressure and capacity rules, testing, flammability classification, the conformity mark and the mandatory particulars before they become enforcement problems. The platform helps you generate and keep the right documentation, and alerts you when obligations change so your compliance stays current.
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Sources and further reading
- Council Directive 75/324/EEC on aerosol dispensers — EUR-Lex
- Sikkerhedsstyrelsen (Danish Safety Technology Authority) — sik.dk
This guide is for general information and is not legal advice.
Last updated: 12 June 2026