The BAMA Bulletin
When is an aerosol
not an aerosol?
The Circular Economy puts packaging under investigation
and BAMA investigates a circular loop for aerosol cans…
Back in 2018, working with the French Aerosol Association
(CFA), BAMA held a workshop to discuss what the pros
and cons might be of a refillable aerosol pack. Since then,
we have held three more workshops and have had interest and
participation in our discussions from around the world.
After Workshop 3, a lengthy report was produced that narrowed
the focus of our discussions into three possible routes to market:
1. The user or consumer refills and repressurizes the pack in
the workplace or at home;
2. The pack is returned to store where it is refilled by an in-store
system; or
3. The pack is returned to store where it is collected, stored and
then shipped back to a filler to be refilled.
It’s fair to say that the discussions at all three of the first workshops
tended to focus on the technical aspects of refillable technology.
We looked at some of the regulations that govern existing aerosol
products and at those that sit alongside aerosols that may be interesting
to consider further. These included those around chemicals
under pressure and transportable pressure devices.
What was missing from these discussions was what interest there
might be from consumers—those who use aerosols in a professional
capacity such as in the industrial and engineering sector and those
who use in the home environment—and how retailers will need to
be involved. It’s safe to say that no matter how clever or unique a
technology, if no one uses it then it is doomed to failure. The history
of consumer products is littered with the carcasses of the “next
best thing.”
Equally, if retailers are not prepared to be involved, marketers
and manufacturers have no way of getting their product out to
the market, or in the case of reusable and refillable systems, back
from it. This is true of both traditional brick-and-mortar retail and
online shopping.
To consider both of these subjects, BAMA set a challenge for a
group of MBA students at Cambridge Judge Business School to
look at the feasibility of refillable aerosols in the industrial sector.
We also approached packaging consultant firm The Pack Hub
and research center The Retail Institute to look at how they might
help, given their experience in these sectors and contacts beyond
BAMA’s traditional base.
Early this year we will have the report from the MBA students,
and this will be shared with BAMA’s Packaging & Contents and
Environment & Sustainability Committees. We also held Workshop
4, which had presentations from The Pack Hub and The Retail
Institute with proposals for next steps in consumer and retailer
engagement.
Back to the original question: When is an aerosol not an aerosol?
This might seem rather a strange question because if it walks like
a duck, and it quacks like a duck, then it is a duck. However, there
are legal definitions of what an aerosol is within specific aerosol regulations
such as the EU Aerosol Dispensers Directive (ADD) and
the UK Aerosol Dispensers Regulations. Aerosols are also defined
in the Globally Harmonized System of Classification & Labeling of
Chemicals/Classification, Labeling & Packaging (GHS/CLP) and
in transport regulations such as ADR (the European agreement
concerning the international transport of Dangerous Goods by Road).
All of these regulations require the product that is sold to the
user or consumer be single use. So, a refillable aerosol is not an
aerosol as defined in regulations used in our industry, and with
good reason. Having a non-refillable pack allows our industry to
minimize the packaging while maximizing safety. We can set up
manufacturing systems to produce very cost-effective products and
put in place processes to encourage and ensure recycling.
We can make well-informed decisions about the formulation,
material choices, coatings, valves systems and the usage pattern of
a product designed to be used once, albeit with multiple applications,
and then recycled. It is much harder to define and predict
how a refillable or reusable product may be “used and abused” by a
consumer to give an equivalent level of safety.
We also need to understand whether a pack that is filled, and
refilled, offers any environmental/sustainability benefits compared
to the widely recycled products on the market today. For example,
how many times would a pack have to be reused to ensure it has a
better carbon footprint than a current non-refillable aerosol?
These questions bring us back to needing to have a better
understanding of how such products would come to market, how
consumers might buy into the concept and whether retailers are
interested. Answers to these will inform us about the technology
and systems needed.
At BAMA’s Committee meetings in 2021 we will make some
decisions on the next steps. Assuming we want to progress with
The Pack Hub or The Retail Institute, we will need involvement
from everyone in the industry. Spray
22 Spray January 2021
Patrick Heskins
Chief Executive
British Aerosol
Manufacturers’ Association