As a trained expert in cosmetic chemistry and nail product safety, I frequently receive inquiries from nail industry professionals wanting to know how they can ensure their products are not only effective, but also comply with strict safety and regulatory standards.
One such question recently highlighted the difficulty of developing nail art paints using an airbrush medium that is labeled as non-toxic but lacks transparency regarding its ingredients. Combining this medium with FDA-approved pigments raises important considerations about the term “cosmetic grade” and what it actually means for product safety and market readiness.
In this article, we discuss key aspects of ingredient transparency, regulatory compliance, and specific challenges related to cosmetic formulation and labeling in the nail industry. The focus is to help professionals navigate the complex regulatory environment, ensure their products meet required safety standards in the U.S. and abroad, and understand why comprehensive knowledge of both ingredients and regulations is essential to succeed in this field. By clarifying these elements, we hope to arm nail technicians and manufacturers with the knowledge they need to confidently produce and sell safe, compliant cosmetic products.
Ensuring Ingredient Transparency on Nail Product Labels
This question is broad and I can’t tell you everything you need to know, but I’ll try my best to answer it, and I’m sure others have similar questions.
First, don’t be fooled by the claim “non-toxic,” as it’s a marketing term without a clear definition. Anyone selling cosmetics needs to know their ingredients so they can list them on the label and in the product’s Safety Data Sheet or SDS (also known as MSDS). They also need to ensure that the ingredients are not banned and determine the appropriate ingredient names to put on the label. This information comes from the International Dictionary of Cosmetic Ingredients (INCI Dictionary), a list of names of cosmetic ingredients.
Product manufacturers must ensure that all ingredients they use are listed on the label and that the correct INCI names are used for all ingredients. Unless they have trade secret status, they may not be allowed to avoid listing ingredients by claiming that a cosmetic is a proprietary blend, but it’s difficult to make that claim if you don’t know the ingredients. Still, if you don’t list the ingredients, you can’t sell your product outside of the United States, because Europe, Canada, Australia, and Japan all insist on knowing the ingredients. Also, anyone bringing a new cosmetic to market is expected to ensure that all ingredients are cosmetically safe and not restricted for use in cosmetics.
The Importance of FDA Approval for Cosmetic-Grade Colorants in Nail Products
Because the nail technician who asked this question lives in the United States, it is very important to her to make sure that the colors and pigments are approved by the FDA specifically for use in cosmetics. This is what is meant by the term “cosmetic grade.” To avoid repetition, we use the word “colorant” to refer to anything that is intended to impart color, such as liquid dyes or solid pigments. It is very important to understand that while the FDA and other agencies in various countries approve a large number of colorants, most are not approved for cosmetic use. They represent a different “grade of material” that is considered not cosmetic grade.
This is usually due to the chemical composition of the substance and its intended use. Non-cosmetic colorants may not be safe for use in nail products and should be avoided. For example, if nickel-based non-cosmetic pigments are used in nail products, they may cause an allergic reaction in people with nickel allergies. It is estimated that one in ten women in the United States has a nickel allergy, primarily due to wearing cheap jewelry that is nickel plated. You can see how this can be a problem.
A relatively small number of colorants are considered safe for use in cosmetics, and many countries strictly regulate and control the use of all cosmetic colorants. Only colorants that are specifically approved for use in cosmetics can be added to any cosmetic product, including artificial nail products. Colorants that are not specifically approved for use in cosmetics cannot be added to a cosmetic product. This is a globally accepted concept, as the EU and other countries have similar requirements as the US.
Ensuring safety and compliance with labeling standards for nail products
Product distributors are also required to prepare, actively distribute and regularly update Material Safety Data Sheets for nail professionals who use their products. While these are basic requirements, it is important to understand that all distributors are not only responsible for providing safe products, but also for providing safe usage instructions, warnings and precautions.
Warnings and precautions must be prominently displayed, meaning they must be visible and readable by nail technicians. Everyone who sells cosmetics in the United States must package them in accordance with the Fair Packaging and Labeling Act, a federal labeling law. Other countries have similar packaging standards. For more information about this law, Federal Trade Commission website Use our handy search box feature to search for “Fair Packaging and Labeling Act.”
The Important Role of Regulatory Consultants in the Nail Cosmetics Industry
My recommendation to anyone considering selling cosmetics in the nail industry is to find a good regulatory consultant to ensure your product and packaging meets the requirements for each location/region it will be sold in. This is very important.
You can also get referrals from many cosmetic associations, such as ICMAD and PCPC. ICMAD is Independent Cosmetics Manufacturers and DistributorsPCPC is Personal Care Products CouncilBoth have websites, and both can connect you with knowledgeable regulatory experts.
Every country has its rules and regulations that must be followed. So now you see that it is a myth that cosmetics are unregulated. Ha! There are so many regulations, some people think there are too many, but for others there are never enough. There are always people who try to impose unnecessary regulations on top of the existing ones, but I think this is a foolish waste of time and resources.
The Complexity of Cosmetics Regulation and Its Importance for Product Safety
Cosmetics are more heavily regulated than some activist groups would have you believe. You may not have realized it was that complicated, but it’s actually a lot more complicated than it seems. That’s why we recommend that anyone selling cosmetics consult with an expert on cosmetics regulation to ensure they’re doing the right thing. Regulations and standards for arts and crafts are completely different from the requirements for cosmetics. Some people confuse the two, but this should be avoided.
What I mean is, some people ask why art and craft stains and glitter aren’t safe to use when the product websites, literature, and safety data sheets say they are “safe.” This is because some people don’t understand that the stains are safe for their “intended use” in arts and crafts, but not in cosmetics. Just because they are safe for use in craft projects doesn’t mean they are safe in nail products or other cosmetic products.
Inhaling shavings or dust containing non-cosmetic colorants can cause problems for nail technicians. Also, overexposure can cause some pretty serious allergic reactions. Whenever an ingredient is purchased for use in cosmetics, the manufacturer should make it clear to all companies that the ingredient is for use in cosmetics and explain its intended use. That way, the ingredient manufacturer can let companies know if it is approved for use.
Anyone who makes or sells cosmetics has to do a lot of things, most of which are to ensure that their products are safe when used as directed. Because making and/or selling cosmetics is a serious business that comes with great responsibility, it is advisable for all involved to ensure that they comply with all requirements.
