How to Store Aerosols Under APQ 10
In Spain, aerosols are stored under ITC MIE APQ-10 of Royal Decree 656/2017, the country's chemical storage regulation. For flammable aerosols the rule applies from 50 litres and requires a full project from 300 litres indoors or 500 outdoors. For non-flammable ones it applies from 200 litres, with a project from 1,000. Below that, following the safety data sheet is enough.
Does APQ-10 Apply to Your Store?
APQ-10 is the complementary technical instruction of the Chemical Storage Regulation approved by RD 656/2017 that governs the storage of hazardous chemicals in mobile containers: drums, jerrycans, cylinders and aerosols too. The other instructions, APQ-0 to APQ-9, cover other products and forms of storage; for an aerosol it is always APQ-10.
The regulation applies to industrial and logistics warehouses and to the stores of businesses not open to the public, in new installations and in extensions or modifications of existing ones.
To know whether it applies to you, answer two questions: is your store in Spain, and is it an industrial or logistics warehouse or the store of a business not open to the public? If both answers are yes, count your aerosols with the table in the next section. If your store is in another country, that country's own storage rules apply, and section 7 of the safety data sheet still says how to store each product.
Cosmetic aerosols count as well. Finished cosmetics fall outside the regulation, but the technical guide of Spain's Ministry of Industry makes an express exception for aerosols: their classification as an aerosol prevails over their use or form, so they must comply with ITC MIE APQ-10 (Ministry of Industry technical guide, 2023).
How Many Aerosols Can You Store Without a Project?
ITC MIE APQ-10 sets two thresholds per type of aerosol: when the rule starts to apply and when a full project is required.
| Aerosol | Hazard statement | Applies from | Project indoors | Project outdoors |
|---|---|---|---|---|
| Flammable, categories 1 and 2 | H222 or H223, with H229 | 50 L | 300 L | 500 L |
| Non-flammable, category 3 | H229 | 200 L | 1,000 L | 1,000 L |
Between the two figures, the project is replaced by a technical report signed by the owner plus a certificate from an authorised inspection body. Above them, a project by a qualified engineer and the site director's certificate are required. In both cases the regional government is notified before the store goes into service, with civil liability insurance of at least 400,000 euros per claim.
Quantities are counted in litres, as the Ministry's guide does in its examples, and they add up within a single fire compartment: 200 litres spread across the benches and shelves of one building are one store, not many small ones. If flammable liquids are also kept, the fractions of each threshold add up, so 25 litres of flammable aerosols and 25 of an H225 liquid already reach it.
Below 50 litres the store falls outside the regulation, but the manufacturer's safety measures still apply, at minimum those in the safety data sheet.
How to Lay Out a Flammable Aerosol Store
Flammable aerosols form an independent compartment separate from any other activity, and they may be kept in a closed store, an open store, a safety cabinet or a modular container. Access is restricted and announced with a visible sign.
- Maximum stack height
- 4.5 m
- Gap between stacks
- 1.2 m
- Exits from a closed store
- at least 2
- Route to the exit
- 25 m at most
- Type 90 cabinet
- up to 250 L of aerosols
- Extinguisher by the cabinet
- rating 34A 144B
Ventilation, natural or forced, is mandatory; inside a building it is ducted outside through dedicated ducts, and forced ventilation needs a failure alarm. The cabinet must be certified as type 90 to UNE-EN 14470-1 and carry a flammable sign, and it counts as a fire compartment of its own.
To store aerosols with other products, the instruction points to its joint storage table and to the safety data sheets: a different extinguishing agent, another temperature or a dangerous reaction means separating them. Boxes packed in limited quantities under the ADR fall outside those joint storage criteria.
💡 Manufacturer's tip: take your inventory in litres and per fire compartment, not per building; moving part of the stock into a type 90 cabinet can leave the rest below 50 litres.
Inspections and Certificates APQ-10 Requires
The store needs a maintenance plan with a named person in charge and a log of checks: ventilation, lighting, shelving, signage, spill containment and fire protection. Every year the installation is reviewed, by an in-house inspector or an inspection body, and a certificate is issued.
Every five years from commissioning, the owner submits to the regional government a certificate from an authorised inspection body confirming the store still complies. Breaches are penalised under Spain's Industry Act and can lead to a temporary shutdown of the activity.
The classification that decides which row of the table applies to you is in each aerosol's safety data sheet. When we handle your aerosol contract manufacturing, we prepare that sheet along with the technical one, so you know which row each product counts under.
