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All about Neon /UV "Face" Paint Regulations

Neon Face Paints

We get a lot of phone calls and e-mails from customers with questions about Neon and Glow in the Dark paints. We created this post to use as a quick guide to help you decide if you want to use these types of paint, and to understand the FDA guidelines concerning their use as a cosmetic. 

Their Properties

The first thing we need to do is define some common terms so that we know what we are talking about from the get go. 

Neon: although, in the face painting and Special Effects (SFX) world we use this term to refer to UV reactive paints, by definition it is a colorless odorless mostly inert gaseous element that is found in minute amounts in air and is used in electric lamps. Technically our paints are not neon, though they appear to glow like a neon light, and most are labeled as Neon. 

UV Reactive: it is a product that glows under black light. This product needs the presence of a black light to glow, and it won’t glow without one. UV reactive paint can also be called luminous paint or fluorescent paint. 

Day-glow: most of our neon paints are day-glow, meaning they also have a glowing effect under regular day light, these are Special FX Paints and not considered a cosmetic in the USA and Europe. That is not the case for those brands that use the only set of FDA approved neon pigments in existence, since those pigments only glow under black light and are very dull under regular light.

Glow In The Dark: these kind of paints don’t need a black light to glow. They only need to be exposed to regular light to be charged. Once charged, they will glow in a dark room. They also react under black light, but a black light won’t charge them, so exposure to black light won’t help to make them glow in the darkness afterwards. Glow in the dark paints are only good when used in large surfaces. Small detailed work can rarely be seen because the glow is not as intense as it is when the surface covered is much larger. Also, they are usually not very good for line work due to their creamier consistency.

So, when a paint company calls their paints Neon, or UV, or DayGlow or Fluor most of them are referring to the same property: they glow under black light. 

Now that we know what the product is and what the differences are, we can talk about cosmetic regulations.

Cosmetic Regulations

In the USA, only a few UV reactive pigments have been tested and approved by the FDA to be used in cosmetic products. Those pigments are not very vibrant under regular light but they glow well under black light. Also, the color range is very limited. 

UPDATE: as of November 2022, the range of approved UV pigments for cosmetic use based on the FDA website is:
D&C Orange No. 5, No. 10, and No. 11; D&C Red No. 21, No. 22, No. 27 and No. 28; and D&C Yellow No. 7.
Source: https://www.fda.gov/cosmetics/cosmetic-products/novelty-makeup

There are many UV pigments in the market, a majority of which haven’t been tested yet by the USA FDA to be used in cosmetics, so according to their regulations, any product using them cannot be labeled as a cosmetic and should not be used as a such.

According to the FDA, cosmetics are "articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body...for cleansing, beautifying, promoting attractiveness, or altering the appearance" [FD&C Act, sec. 201(i)].

The fact that the FDA hasn’t tested the pigments yet doesn’t mean that they are in any ways dangerous to the skin. It just means that the FDA hasn’t looked into their safety yet. The good thing is that many companies claim to have conducted their own tests with independent labs and those tests have established that the pigments are safe to be used on the skin, according to these companies.

 

 

Unfortunately, those tests are not enough to make the product compliant with USA FDA regulations.

To meet compliance and make sure that products are labeled correctly within the USA and European markets, face paint manufacturers have decided to label UV/Neon face paints as “Special FX Products, “Not for use on Skin”, or “Prosthetic Paints”, etc. They all have the same intention; warn the customer that the product is not considered a cosmetic in the USA and Europe and should not be used like that. The idea is to use the product over prosthethics, clothes, paper cut outs that are then added to the face, etc.

Diamond FX Neon Paints Label

These regulations change from country to country, in countries like Australia, face paints are regulated as craft paints, so neon pigments are not an issue. Because paints are sold all over the world, but the USA tends to be the biggest market, most companies label their paints to be in compliance with USA FDA regulations. So, if you are in Australia, for example, the “Special FX” warnings don’t apply to your country, but a company in Australia may still use them.

Neon Paints that are FDA Compliant for Cosmetic Use According to the Manufacturers

Diamond FX makes a UV/Neon Violet, Blue and White that are compliant with Cosmetic regulations according to them. Ruby Red has a nice range of colors including: white, yellow, green, pastel green, pastel blue, blue, purple, pink and orange that are also UV and FDA compliant according to them. This is the biggest range of FDA compliant UV/Neon paints available in the market at the moment. Snazaroo also has a small range of colors that comply with FDA regulations according to them. 

Ruby Red also makes a clear UV color that can be applied on top of regular face paint. The color won’t show until exposed to UV lights. Once exposed to Black Lights, it will have a greenish glow with subtle variations depending on the color laying underneath it.

These pigments, as mentioned before, are not as vibrant under regular light as the non FDA complaint pigments used in other brands, but they do glow well under black light.

Kryolan has now launched a new line of cosmetic grade UV face paint colors that are complaint with US and European cosmetic regulations according to them, and we have them available! UPDATE: Kryolan has discontinued their Cosmetic Compliant UV range.

Glow in the Dark Paints that are FDA compliant for Cosmetic Use according to the manufacturers

As far as Glow In The Dark paints the FDA has only approved one pigment with such quality and it is a whitish pigment that has a yellow/greenish glow in the dark. There are some companies offering a much wider range of glow in the dark colors, but they do not comply with USA FDA cosmetic regulations, although some do comply with EU cosmetic regulations.

Mehron, Ruby Red and Endura all produce FDA compliant glow in the dark face paints (based on their claims).

It is worth mentioning that all the of brands we import go through the FDA when they arrive to the country, and the FDA checks regularly for labeling compliance, though this in no way indicates FDA approval. 

Many times, like it happens with Henna, or real Tattoo inks, the FDA is very aware of the use of the product and knows that sometimes they are used in violation of their regulations, but lack of action usually means that they do not consider it an immediate hazard (because they haven’t received many complaints about bad reactions) and so they do not put much effort into stopping the sale and use of those products. The FDA has said before that they concentrate their efforts onto those products that are known for having adverse effects. Again, this still does not mean that the FDA implicitly or explicitly approves the use of these pigments as cosmetics.

The future could change, at some point either the FDA will choose to test those pigments if they consider it a public health priority, or the food and drug industry companies could request an FDA approval after following the steps required by the FDA to do so.

In any case, what is most important is that you know what you are using and buying, and you make informed decisions. We strongly suggest that users of these products follow the label's instructions and use them for what they are intended for, but if you decided to go against the label's instructions, It is not a bad idea to check with your entertainers insurance company to see if you will be covered when using products that are not compliant with USA cosmetic regulations. Many insurance companies don’t have an issue with that as long as the product is regarded as safe (this can be broad, hard to prove and in the end you might not be covered if the product says is non cosmetic and you used it as such). Others have in their language that they require FDA compliant products to be used or that the manufacturer must not advise you on their label that the product is not intended for cosmetic use.

Could Face Paint companies pay to get neon pigments approved by the FDA?

The answer to this question is basically no. The approval process it not as easy as to simply pay, request and get an answer. The FDA has to have an interest in the product, which usually means that there has to be a high demand for that pigment for them to invest their time and resources to look into. In order to request approval of a new pigment the FDA requires extensive testing that is expensive to conduct and can only really be afforded by very large industries like the pharmaceutical or food industry, the two biggest users of FDA approved pigments. 

No Warnings so no Worries?

We have noticed from reading posts online that many customers believe that if the product has no warnings on the website they buy it from, or on the label, even though it is neon, then everything is ok. There is something to be said about that. If the product comes from a reputable vendor and it is of a well known brand, likely the product is indeed safe (but we can't guarantee that). But, if the product clearly has UV pigments yet the manufacturer doesn't disclose them and you see no warnings on their label, that doesn't mean that the product is FDA compliant, or UK and EU compliant. It might likely be FDA compliant, if the pigments used are the ones that look dull under regular light, or It just means that the manufacturer chose to conceal that information from you. We see many eye shadow palettes coming from abroad that when exposed to UV lights glow like a disco party (and also glow under day light), yet they have no information at all on UV pigments being used. If you got a UV reactive face painting product that has no label warnings, ask the manufacturer what UV pigments did they use. Currently, the only FDA approved pigments that are UV reactive are: D&C Orange No. 5, No. 10, and No. 11; D&C Red No. 21, No. 22, No. 27 and No. 28; and D&C Yellow No. 7. You can mix these pigments with regular non UV pigments to obtain other colors, so for example you can mix UV Yellow No. 7 with a regular blue pigment to obtain a UV green, but it won't be a day glow kind of green, it will be dull looking under regular light. So, for example, If you see a product with a UV reactive green that also glows under regular light, it is likely made with non FDA approved pigments.

We applaud those manufacturers that are open and honest with their users about their products and what current regulations say about them and labeling them accordingly.

If you want to MAKE SURE that a company's claim that their UV/Neon products are FDA, UK or EU compliant, then you should ask for:
- Lab tests from a lab that you can reach out to and confirm tests are real, that prove they tested the pigments and confirm such pigments were present on the product (not a certificate that says that the ingredients presented to them are compliant... there is no tests done with those certificates).
- List of pigments found on their UV cakes.
- Then go to the UK, EU or FDA site, depending on where you live and see if in fact those pigments are approved.
- Then do an online search for manufacturers of those pigments and see how they look in real life, pictures of them, to see if they match the colors on your cakes.
- Lastly, check if the list of pigments provided make sense: for example, if they gave you the list of pigments for a UV green, does it contain a UV green pigment?

We are almost certain, in our opinion, that most companies making this claim won't be able to prove their claim from the looks of their products which clearly, in our opinion, come from one of the 2 factories in China that we know of that produce this kind of paint, and those shades just look like the ones all other brands coming from those factories have that are not FDA, EU or UK compliant in our opinion (with the exception, in our opinion, of Ruby Red which we have seen their ingredients list and the pigments listed in our opinion match the colors made and clearly look different than the non compliant neon colors).

If you are buying from a marketplace (Amazon, Walmart, Ebay, Alibaba, Aliexpress, etc) be EXTRA careful. Most of those companies don't exist other than there. You have no way to reach them back in case of an allergic reaction, no way to sue them as many have headquarters overseas in Asia and no legal presence in your country, etc...

Better to always buy from reputable dedicated sites that served on our industry (not just our site, but any professional face paint store) and that has the correct warnings posted on their site.

In our case, regardless of what the brand tell us, if they have not provided us with something that shows that their claim makes sense and is true, we keep the neon compliance warning on our site. We sell worldwide, and in some countries those warning don't apply, but in others they do.

When a company tells us their neon colors are FDA compliant, we ask to see the ingredients list, we look for each ingredient on the FDA site, make sure they are compliant, and we then double check that with those pigments listed you can actually produce the color they are producing. In the end, the responsibility falls on to them for what they put on their labels, but we want to do our best to provide our customers with the most accurate information we can within our means.

About 11 years ago we at Jest Paint started to research this topic and required manufacturers to learn more about their products and to label the products according to our regulations in the USA. At the same time we were first to openly disclose those warnings on our website so customers knew before they spent their money and could make an informed decision. Once we made the move, many stores followed, and today we are happy to say that most stores disclose that information up front. We do encourage you to ask your retailer to post those warnings on their website, just because they are not posted it doesn't mean that the product label won't have them.

Should I and Can I Use Neon Paints?

The warnings given by the manufacturer's are clear and they explicitly say what the products are intended for. We can't force a customer to use a product the way is expected to be used, that is a personal decision for you to make. No government agency has determined yet the pigments to be unsafe (like for example with the pigment used in the so called "black henna" which has been determined a very dangerous pigment), but that is not the same as saying they are cosmetic grade. The situation with neon paints in the USA is the same as with regular henna and regular tattoos: the pigments are not approved by the FDA to be used in that way, yet the FDA knows every one uses them like that, and the FDA has not done much to prevent it because in our opinion they don't consider it a high risk, they usually take immediate action when something is a high risk. But again, that in no way is a suggestion that you should go against label's instructions.

Also, keep in mind the products are OK to use as labeled, on clothes, prosthetics, hair or nails based on the manufacturer's individual claim, just read the label.

A side note: FDA complaint vs FDA Approved

The FDA doesn't approve a finished cosmetic product. No matter what some manufacturers might say, their cosmetic products cannot be FDA approved. The FDA only approves pigments to be used in cosmetic applications. Those pigments can be used by any cosmetic company. 

If a cosmetic product uses FDA approved pigments for cosmetic use (certified or not depending on the specific pigment) and complies with all other label and ingredients regulations, then the product is in itself FDA Compliant. Companies cannot submit a finished cosmetic product to the FDA to get their approval, that is why claiming to have done so is incorrect. Companies can only say that they comply with, meet or follow FDA regulations.

At any given time, if you have questions about a pigment used, you can check the FDA list of approved pigments on the FDA website.

You can check our entire range of neon paints as well as special fx neon paints on our website.

Feel free to contact us if you have any other questions, we are always happy to hear from you.

Disclaimer: these are opinions based on our personal experience, we are not lawyers, chemists or health officials, so we recommend for you to contact a professional before making any decisions. We are not in any way giving legal or health advice and we are not liable for any decisions you make or stop making based on the opinions provided above. We are also not making particular claims about any one company in particular, just providing our opinion based on our experience, and we encourage you to find the facts on your own.

NOTICE: at our store we sell not only face and body paints and tools but also Special FX (SFX) products designed to be used for special effects only. UV/Neon colors that have that notice on their description and/or name indicate that they are not considered a cosmetic product within the USA and Europe. These neon/uv products have yet to bested by the USA FDA for cosmetic safety so manufacturers have labeled them and sell them as a Special FX product to be used on clothing, over prosthetics, etc to create a black light glow effect. This warning does not apply to all countries that we sell to, please look into your own country's regulations for neon face paints. Any Neon/UV paint without that warning has been determined to be cosmetic compliant by the manufacturer. At Jest Paint we don't label these products and are not responsible for manufacturer's claims or label's compliance, but we do our best to make sure that the label information provided to us is available on our website as well. If you have questions please contact the manufacturer directly.

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Comments

M Vaughan - August 21, 2023

Thank you for all the through and interesting information in your article. I have been totally confused since I first started face painting about this subject. Some painters seem to of been using various neon pigments for years presumably without ill effect – at least nobody talks about it. It would be helpful if retailers separated the non neon from the neons so customers didn’t order items they can’t use ( under the rules of their insurance), this would extremely useful.

Sherry - June 16, 2020

I bought a Fusion Body Art palette – one of the new most popular ones – from another source and just noticed today the Special FX Product warning on the label. I wish I hard read this article before purchasing the product. I really appreciate the thorough nature of this article. Now I have to go see if my particular insurance will cover my using this product. I am now “informed” – thanks to your article – and will be much more cognizant of purchases going forward. BTW – this is NOT a slam at Fusion Body Art or the vendor – I was the one who didn’t understand and it is my responsibility to be informed. The colors are absolutely stunning and while I am not concerned personally with using neon on my own skin – I want to be especially cognizant of what I offer/use with my customers. Thank you again for a very well written article about this subject.

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