CPGShield resources · Ingredient compliance
A cheek tint that also works on lips and eyelids is an appealing product idea. It can simplify a customer's routine and give a founder a clear story for a new launch.
But adding “eyes and lips” to the directions is more than a copy change. It creates additional questions about the color additives in the formula.
For U.S. cosmetics, permission to use a color in one application does not establish permission for every application. Check each intended use before turning a single-purpose product into a multi-use one.
FDA explains that eye-area use must be specifically permitted for the additive. It also explains that “externally applied” does not include the lips or surfaces covered by mucous membranes. Both restrictions apply whether the color requires batch certification or is exempt from it. FDA's color-additive fact sheet explains the distinction.
That is why a supplier's broad description, such as “cosmetic grade,” is not enough to decide where your finished product can be used. Ask for the exact additive identity and the applicable use information.
FDA's reference table lists ultramarines for eye-area and external use, but not for the general category that includes lipsticks. Iron oxides appear with permission across all three table columns. The individual regulations still control specifications and conditions. These entries illustrate why one color's permissions cannot be transferred to another. FDA's permitted-color table links to the relevant regulations.
This example is not a recommendation for a particular formulation. Before using a material, evaluate its exact identity, specifications, intended use and current regulatory status with the supplier and an appropriate reviewer.
Create one row for every color additive in each shade. Give the row a separate decision for cheek use, lip use and eye-area use, with a source and an owner for unresolved questions.
Include the precise form supplied. If a blend contains several coloring components, ask for enough detail to review those components. A marketing shade name such as “Rose Glow” does not identify the substances that create it.
Then compare the matrix with the launch brief. If the brief promises three application areas but the formulation review supports only two, resolve the mismatch before the designer turns it into package copy.
The same method helps when expanding an existing range. Review the new shade on its own information instead of assuming that a previous shade's review covers the whole collection.
Some colors require FDA batch certification; others are exempt. Exemption does not remove the applicable identity, specification and use requirements. A Colour Index number by itself does not establish that a batch subject to certification was certified. FDA's fact sheet covers these checks.
In practice, ask your supplier which category applies and what documentation connects the supplied lot to that answer. Store that information with the material's purchase and receiving records so someone can retrieve it without relying on a sales conversation.
Once the intended uses are settled, compare the package directions with the product page, application photography and creator brief. A label limited to cheeks can become confusing if the accompanying demonstration tells customers to apply the product to their eyelids.
FDA considers promotional claims and other evidence when determining intended use. Its cosmetic and drug classification guidance explains that broader principle.
Give your designer and marketing team a short statement of the reviewed application areas. When someone proposes an additional use, reopen the product review instead of treating it as a harmless edit.
No. Color review is one part of the product review. The finished formula, label, intended uses and supporting records still need attention.
Build the review around the actual composition of each shade. Shared packaging or a shared base formula does not establish that the colors are identical.
Start with FDA's current permitted-color table, then follow its links to the individual listing regulations and compare those requirements with supplier documentation.
Run your makeup label through CPGShield free as part of that review. Keep the supplier records available: a printed ingredient list alone cannot establish a material lot's certification or specifications.
For the broader review, see ingredient restrictions and hazard checks and federal rules versus retailer criteria.
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