As a seasoned expert in cosmetic chemistry and nail product safety, I often encounter queries from professionals in the nail industry who are eager to understand how to ensure their products are not only effective but also compliant with stringent safety and regulatory standards.
One such question recently highlighted the challenges of developing a nail art paint using an airbrush medium labeled as non-toxic, yet lacking in transparency concerning its ingredients. This medium, combined with FDA-approved pigments, raises important considerations about the term “cosmetic grade” and what it truly entails for product safety and market readiness.
In this article, I will address the critical aspects of ingredient transparency, regulatory compliance, and the specific challenges associated with formulating and labeling cosmetic products in the nail industry. The focus will be on helping professionals navigate the complex regulatory landscape, ensuring that their products meet the safety standards required in the U.S. and abroad, and understanding why comprehensive knowledge of both ingredients and regulations is essential for success in this field. By clarifying these elements, I aim to empower nail technicians and manufacturers with the knowledge needed to confidently produce and sell safe, compliant cosmetic products.
Navigating Ingredient Transparency in Nail Product Labeling
This question covers a lot of territory, so I couldn’t tell you all that you need to know, but I’ll do my best to answer. I’m sure others have similar questions about this.
First, “non-toxic” is a marketing term with no real definition, so don’t be impressed by this claim. Anyone who sells a cosmetic product is required to know the ingredients, so they can list them on the label and on the product’s Safety Data Sheet or SDS (aka MSDS). They also must make sure the ingredients are not prohibited and determine the proper ingredient name to place on the label. This information is obtained from the International Dictionary of Cosmetic Ingredients (INCI Dictionary) it’s a list of names for cosmetic ingredients.
Product manufacturers must ensure that all ingredients used are listed on the label and the correct INCI name is used for all ingredients. It is unlikely that any cosmetic product would be allowed to avoid listing the ingredients by claiming that it’s a proprietary blend unless you have trade secret status and that is a hard claim to make if you don’t know the ingredients. Even so, without the ingredient listing, the product couldn’t be sold outside the US, because Europe, Canada, Australia, and Japan will all insist on knowing the ingredients. Also, anyone who brings a new cosmetic product to market is expected to ensure all ingredients are safe for cosmetic use and not restricted from use in cosmetics.
The Importance of FDA Approval for Cosmetic Grade Colorants in Nail Products
Since the nail technician who asked this question is in the USA, it would be very important for her to ensure the colorants and pigments are FDA approved for use, specifically in cosmetics. That’s what is meant when the term “cosmetic grade” is used. To keep from being repetitive, I’ll use the word “colorants” to mean anything that is intended to impart color, including liquid dyes and solid pigments. It is very important to understand that the FDA and other agencies in different countries have approved a large number of colorants, but most are not approved for cosmetic uses. They represent a different “grade of material” that is considered non-cosmetic grade.
This is usually due to the chemical composition of the substance and how it is intended to be used. Non-cosmetic colorants may not be safe for use in nail products, so they should be avoided. For instance, if a non-cosmetic pigment which is based on nickel were used in nail products, it could trigger allergic reactions in those with nickel allergies. It’s estimated that 1 in 10 women in the US have nickel allergies, largely from wearing inexpensive jewelry that is plated with nickel… so you see how this could be a problem.
Only a relatively few colorants are considered safe for use in cosmetics and many countries closely regulate and control the use of all cosmetic colorants. Only those specifically approved for use in cosmetics may be added to any cosmetic product, including artificial nail products. Those that are not specifically approved for cosmetics are NOT allowed to be added to cosmetics. The EU and other countries also have requirements similar to the US, so this is a universally accepted concept.
Ensuring Compliance with Safety and Labeling Standards for Nail Products
Product sellers are also required to develop and actively distribute product Safety Data Sheets to nail professionals who use their products and to update these sheets regularly. Those are the basic requirements, but it is also important to know that all seller are responsible to provide safe product, as well as to provide safe usage directions, and any warnings or precautions.
Warnings and precautions MUST be prominently displayed, which means created so that nail technicians can see and read them. Everyone in the USA who sells cosmetics must package them in accordance with the Fair Packaging and Labeling Act, which is federal labeling act. Other countries have their own similar packaging standards. More information on the this act can be found at the US Federal Trade Commission’s website and you use the handy search box feature search for the “Fair Packaging and Labeling Act”.
The Crucial Role of Regulatory Consultants in the Nail Cosmetics Industry
My recommendation to anyone thinking of selling a cosmetic product into the nail industry is to find a good regulatory consultant to ensure that your products and packaging meet the requirements of each place/region where your products are sold. That is very important.
You can check with one of the many cosmetic associations such as the ICMAD or PCPC, for a referral. ICMAD is an acronym for Independent Cosmetic Manufacturers and Distributors. The PCPC is the Personal Care Products Council. Both have websites and both can refer you to knowledgeable regulatory specialists.
There are rules and regulations in every country which must be adhered to. Now you can see it’s a myth that cosmetics aren’t regulated. Ha! There are so many regulations, some think too many, but for some there are never enough regulations. Some are constantly trying to force unnecessary regulations on top of the existing ones, which in my view is a foolish waste of time and resources.
Complexity of Cosmetic Regulations and Their Importance in Product Safety
Cosmetics are more heavily regulated than some activist’s groups would like you to believe. I’m sure some of you are saying, I had no idea it was so complicated. And I’ll tell you the process is far more complicated that it seems. That’s why I recommend that anyone selling cosmetic products to seek the help of a professional who specializes in cosmetic regulations and make sure you are doing things right. Regulations and standards for arts and crafts products are entirely different from cosmetic requirements. Some confuse the two and this should be avoided.
Here’s what I mean- some have asked me why it isn’t safe to use art and craft colorants or glitters when the product’s website and literature and Safety Data Sheet say they are “safe” for use. Some don’t understand that this means the colorants are safe for the “intended use” arts and crafts and that does NOT include cosmetic use. Just because these are safe for use in a craft project, doesn’t mean they are safe for nail products or other cosmetics.
Inhaling filings and dusts that containing non-cosmetic colorants could cause problems for nail technicians. And overexposure can lead to rather serious allergic reactions. Whenever an ingredient is purchased for use in a cosmetic product, the manufacturer should clarify to all companies that the ingredient is for use in a cosmetic and explain the intended purpose is so the ingredient manufacturer could let them know if it is approved for that usage.
Anyone who manufactures or sells cosmetics are required to do many things, most of which help to ensure the products are safe when used as directed. Manufacturing and/or selling a cosmetic is serious business with serious responsibilities, which is why I recommend that all involved ensure they are compliant with all requirements.
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