APA Standard 87-1: Composition Limits, Labeling, and Shipping

APA Standard 87-1 is the industry standard that sets the construction and chemical composition rules every consumer firework sold in the United States must meet. The Department of Transportation incorporates it by reference into the Hazardous Materials Regulations, so any Division 1.4G consumer firework has to comply with APA 87-1 before it can legally move in commerce.1Pipeline and Hazardous Materials Safety Administration. 2018 APA Standard 87-1A Fireworks Brochure The standard covers how much pyrotechnic composition a device can hold, which chemicals are forbidden, how long a fuse must burn, and how the device must be built to stay upright and intact when it fires.

Three federal agencies enforce rules that touch consumer fireworks. PHMSA classifies and approves them for transportation and issues the EX or FC numbers that appear on packaging.1Pipeline and Hazardous Materials Safety Administration. 2018 APA Standard 87-1A Fireworks Brochure The Consumer Product Safety Commission regulates them as hazardous substances under 16 CFR Parts 1500 and 1507, covering prohibited chemicals, fuse burn times, base dimensions, and labels. The Bureau of Alcohol, Tobacco, Firearms and Explosives requires a federal manufacturer’s license for anyone producing consumer fireworks commercially, because the pyrotechnic compositions themselves qualify as explosive materials. ATF does not regulate the importation, distribution, or storage of finished consumer fireworks.2Bureau of Alcohol, Tobacco, Firearms and Explosives. Fireworks

Composition Weight Limits by Device Type

The total pyrotechnic material inside a consumer firework is one of the standard’s fundamental limits. Multiple-tube aerial devices, commonly called cakes, may contain up to 500 grams of total chemical composition, but only when the tubes are securely attached to a base and separated from each other by at least 12.7 millimeters (half an inch) at the top, bottom, and sides.3American Pyrotechnics Association. APA Standard 87-1A – Standard for the Construction, Classification, Approval, and Transportation of Consumer Fireworks If a cake’s tubes have an inner diameter under 12.7 millimeters and each holds less than 5 grams, the spacing requirement drops away. Single-tube aerial devices that don’t qualify as multi-tube cakes are capped at 200 grams.

Fountains follow separate limits by shape. A cylindrical fountain can hold up to 100 grams of composition. A cone fountain tops out at 50 grams. A nitrocellulose fountain is limited to 15 grams.3American Pyrotechnics Association. APA Standard 87-1A – Standard for the Construction, Classification, Approval, and Transportation of Consumer Fireworks These ceilings keep ground-based devices from behaving like aerial fireworks or crossing into the 1.3G professional classification.

The weight limits live in the APA standard itself. They reach consumer fireworks through 49 CFR 173.65, which requires all Division 1.4G consumer fireworks to be manufactured in accordance with APA 87-1.4Federal Register. Hazardous Materials – Revision to Fireworks Regulations Importers and manufacturers document the exact composition weight for each product, because CPSC investigators check those numbers during port inspections and compliance testing.

Flash Powder Limits for Audible Effects

Devices designed to make a bang face the tightest limits. Under 16 CFR 1500.17(a)(3), any firework producing an audible effect with more than 2 grains (approximately 130 milligrams) of pyrotechnic composition is banned as a hazardous substance.5eCFR. 16 CFR 1500.17 – Banned Hazardous Substances The only exception covers wildlife management programs run by the U.S. Department of the Interior or equivalent state agencies.

ATF draws the line more tightly still. Ground devices can contain no more than 50 milligrams of flash powder, and aerial devices no more than 130 milligrams. Anything above those thresholds is an explosive material rather than a consumer firework.2Bureau of Alcohol, Tobacco, Firearms and Explosives. Fireworks6eCFR. 27 CFR 555.11 – Meaning of Terms Devices that exceed these thresholds fall into the same category as M-80s, cherry bombs, and silver salutes. Law enforcement routinely tests confiscated fireworks against these numbers, and even a few milligrams over the line converts a consumer product into an illegal explosive.

Prohibited and Restricted Chemicals

Certain chemicals are flatly banned from consumer fireworks under 16 CFR 1507.2:

  • Arsenic compounds: arsenic sulfide, arsenates, and arsenites
  • Boron
  • Gallates or gallic acid
  • Magnesium in pure form (magnesium-aluminum alloy, or magnalium, is allowed)
  • Mercury salts
  • Phosphorus in both red and white forms (red phosphorus is permitted in caps and party poppers)
  • Picrates or picric acid
  • Thiocyanates
  • Titanium, except in particle sizes larger than 100-mesh
  • Zirconium

These chemicals are restricted because they make pyrotechnic compositions dangerously sensitive to friction, impact, or heat. A mixture containing arsenic compounds or picric acid could ignite during ordinary handling or shipping.7eCFR. 16 CFR 1507.2 – Prohibited Chemicals

Chlorates sit in a middle category. They are generally banned but permitted in three narrow situations: in colored smoke mixtures that contain an equal or greater amount of sodium bicarbonate; in caps and party poppers; and in small devices like ground spinners where total powder content stays under 4 grams and chlorate content does not exceed 15 percent or 600 milligrams.7eCFR. 16 CFR 1507.2 – Prohibited Chemicals The APA standard adds transportation restrictions: mixtures or devices combining a chlorate with an ammonium salt or an acidic metal salt may be classified as forbidden for shipping.

All chemicals in a device must also appear on the Permitted and Restricted Chemicals Table in the 2018 APA 87-1 standard. A composition sheet listing anything off that table will not clear approval.

Fuse, Base, and Casing Requirements

Under 16 CFR 1507.3, a consumer firework fuse has to meet three requirements. It must be treated or coated so it does not catch fire from anything other than deliberate lighting at the tip. It must burn for at least 3 seconds but no more than 9 seconds before igniting the device. And it must be attached firmly enough to hold either the weight of the firework plus 8 ounces, or double the device’s weight, whichever is less, without pulling free.8eCFR. 16 CFR 1507.3 – Fuses Small ground spinners with less than 6 grams of composition are exempt from the side-ignition coating requirement but still have to meet the burn-time window.

The 3-to-9-second window is practical. Any shorter and there is not enough time to move away; any longer and someone is likely to walk back thinking the fuse went out.

Devices designed to operate standing upright need a base with a minimum horizontal dimension of at least one-third of the total device height, including any cap or base affixed to it.9eCFR. 16 CFR 1507.4 – Bases A 12-inch fountain needs a base at least 4 inches across.

The pyrotechnic chamber must be built to function without burnout, where the casing burns through, or blowout, where internal pressure ruptures it.10eCFR. 16 CFR 1507.6 – Burnout and Blowout Both failures are common causes of injury, and CPSC field testers look specifically for them.

Labeling

Every consumer firework carries specific warning text on its label, with wording that varies by device type under 16 CFR 1500.14(b)(7). The general pattern is a signal word (“Warning” or “Caution”), a description of the hazard, a supervision statement, an outdoor-use-only instruction, and directions for safe use.11eCFR. 16 CFR 1500.14 – Products Requiring Special Labeling Under Section 3(b) of the Act A fountain label, for example, says “Flammable” or “Emits Showers of Sparks” and tells the user to place the device on a level surface, light the fuse, and get away. Rockets with sticks must direct the user to place the device in a wooden trough or iron pipe at a 75-degree angle pointed away from people and flammable material. Any consumer firework not covered by a listed category still needs a label describing where and how to use it and the necessary precautions. Missing or incorrect labels are among the most common compliance failures and can trigger a shipment seizure at the port.

Getting an EX or FC Number to Ship

Before a consumer firework can move within the United States, it needs either an EX number from PHMSA or an FC number from a DOT-approved Fireworks Certification Agency. The product ships under the name “Fireworks,” hazard classification Division 1.4G, identification number UN0336.4Federal Register. Hazardous Materials – Revision to Fireworks Regulations Packages certified by an FCA carry the assigned FC number on the marking.

The application requires a diagram of the device showing all internal components, a complete chemical composition sheet listing every chemical and its maximum weight, and results from a thermal stability test. The stability test heats a sample of the device, or its components in contact with each other, to 75°C (167°F) for 48 consecutive hours. The composition must not ignite or significantly decompose during the test.12Pipeline and Hazardous Materials Safety Administration. Procedure for Obtaining EX Numbers Under APA Standard 87-1 The application also carries a signed certification declaring conformance with the standard. If the composition sheet lists a chemical not on the permitted table, or if the total composition weight exceeds the applicable limit for that device type, approval is denied. Shipping without a valid EX or FC number violates the Hazardous Materials Regulations.

Penalties for Noncompliance

When CPSC finds a violation, manufacturers, distributors, and retailers all have to report within 24 hours of obtaining information that reasonably suggests a product either fails a safety rule or contains a defect that could create a substantial hazard.13eCFR. 16 CFR Part 1115 – Substantial Product Hazard Reports A firm uncertain whether an issue is reportable gets a maximum of 10 days to investigate before the clock starts.

Civil penalties reach $100,000 per individual offense, with a ceiling of $15 million for a related series of violations, subject to periodic inflation adjustments.14Office of the Law Revision Counsel. 15 USC 2069 – Civil Penalties Recalls typically require a corrective action plan covering refunds or replacements, product retrieval, and public notice. For products that cross the line into illegal explosives, federal criminal penalties under 18 USC 844 apply, with prison terms of up to 10 years.15Office of the Law Revision Counsel. 18 USC 844 – Penalties