FAQ on Day Glow and UV face paints

Day Glow, Neon & UV Pigments in Cosmetics...

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First a word from Gary Cole from SNAZAROO USA Inc. and after words some comments from JoJo from FPHQ. Please read both in full and check out all of the links for even more information.

I'll start off by stating that the issue with the so called "Day Glow", "Neon" and "UV" face paints are a controversial issue. It is something that comes up over and over on the discussion list for face painters. I thought that I'd take the time to address this issue from a FDA perspective. Yes I am very aware that there are several brands of "name brand" face paints that openly market their day glow and UV paints. However, the bottom line is many of pigments used in these products SIMPLY DO NOT COMPLY WITH THE FDA as approved. If you look closely at the labels you with see a labeling that states "for hair or special effects" rather than FDA approved or "cosmetic". Legally they can not be approved as a cosmetic because they are using pigments that are not found in the list of approved cosmetic ingredients (see also http://www.snazaroo.us/safety.htm ). It is against the law to use these pigments in a cosmetic product in the United States, the United Kingdom, Canada and Mexico. I'll also note that many countries, Germany for example, have much more lenient laws than the United States. What is approved there can often be banned as unsafe here in the United States. This FAQ is not to debate if one countries cosmetic laws are better or safer. Our point is in the United States market SNAZAROO takes the higher road. If it can not meet both the US and EU cosmetic laws then we will not offer the product. I know that when I use "the other brand" in their range of UV colors four out of the seven colors break me out. You choose for yourself as ultimately you will be the one held accountable when you get the angry call from the parent. Some of the huge red flags are the fact that they do not legally demote the pigments used as required by cosmetic laws. Instead they list as "pigments" or "ASTM Pigments" or leave off totally any acknowledgement of ingredients. I'll also point out that toxic ingredients like turpentine meet art standards for the ASTM. That is a standard for art products and NOT cosmetics. Another key element is these manufacturers leave off the ingredient formaldehyde which is a brightening agent for neon, day glow or UV pigments. Snazaroo does not use any formaldehyde in any of its formulas but almost all other brands do despite the fact they do not list it as an ingredient. In decades gone by formaldehyde was used in cosmetics and hair care products. This policy has gone by the wayside once it was discovered that formaldehyde was a known carcinogen. You don't have to take my word for it. Smell the other brands as you can smell the formaldehyde in the formula. In the other brands formaldehyde is used as a brightening agent to bring out the bold neon/ day glow colors. Do you really want to use a known carcinogen on your skin or your face painting customers? Do an internet search for "formaldehyde", "fluorescent" and "brighteners". You will find data to back this up.

Yes, you will find many that have been using these products for face painting for years and years with no known side effects. Keep in mind that many people smoke all their lives and still don't get lung cancer. One, at times, has to take the high road and understand that the FDA (food and drug administration) might know a little more than we do about safety. There may be a point that someone comes up with the tens of thousands of dollars needed to do the safety testing but to date no one is willing to do this. SNAZAROO has always opted to avoid those products or ingredients that can not pass both the United States FDA as well as the European equivalent. These pigments are approved for use in cosmetics in countries such as Germany but they continue to be on the banned list of pigments by the USA, UK, Canada and Mexico. SNAZAROO would love to make these day glow and UV face paints available, but to date, we have opted to stand by the experts at the FDA. In December of 2005 the FDA did approve a range of UV pigments that are safe for use on the face. With those pigments we developed a range of four colors (red, pink, orange and yellow called the Cosmic range). The Snazaroo UV colors comply fully with all cosmetic requirements and also are the only brand that has a child toy safety rating. We have MSDS reports to back this up.

I defer to an article by Christopher Dane, Chairman, Swada (London), titled "Fluorescent colour and cosmetics" link http://www.atalink.co.uk/csb2000/html/art_rawmats_swada.htm where he says simply that most fluorescent colors are not approved by the FDA. You will need to refer to the article and the link because we can not reprint more because it is a copyrighted article.

The bottom line is these pigments are not LEGALLY allowed to be used in any cosmetic product for the skin. The exception is the four colors noted above. Even then, there are defined limits on those pigments and they should avoid the use of color enhancers like formaldehyde which these other brands use. Formaldehyde is a know carcinogen. There is plenty of documentation on this on the internet. You do not have to take our word on it. Do the research yourself and you will find formaldehyde should not be used in cosmetic products. If you smell these other brands you can smell the slight odor of this color enhancing agent. Companies might skirt the issue by some deceptive labeling but the pigments simply are not approved for use in cosmetics. If you read in the volume two of "Face Painting International" (page 36-37), you will see an article written called "kool for nights" written by Wolfman Langer the president of KRYOLAN Corp. Int. (in regards to their day glow / UV line) he said, "The dye normally consists of safe substances, although they are not part of the recognized list of cosmetics. According to cosmetic regulations, only an approved list of pigments may be used in cosmetics for the skin. According to the definition a color cosmetic item is a product which is purposely applied to the human skin to create or change the color image. With Day Glow Colors, the dye is embedded in a resin and has no direct contact with the skin. Day Glow Colors are in this way considered as color pigments. However, none of the existing pigments IN THOSE FORMULAS has ever been officially approved for cosmetic purposes. The exception is, they are used as legal color additives in nail polish and hair sprays." The question I would pose to anyone is are you going to use these pigments on the nails or on the hair? If not the FDA has stated that they are not approved. According to the FDA you SHOULD NOT USE THEM ON SKIN. Be very careful with any brand of cosmetic you use and get the facts on the pigments that they use. Seek specifically for UV pigments that are approved for cosmetic use in the United States and the European Union. Also avoid any cosmetic product that contains formaldehyde. You would be personally liable should there be any allergic reaction or any other adverse reaction of any kind. You would be using these paints knowing that they use pigments banned by the FDA. You have no product liability since you use them on the skin versus the labeling stating "hair or special effects". Your own entertainer's insurance would also not protect you since you are using a product outside the labeling criteria.

I do think it is only a matter of time before we see these pigments (including green, blue and purple) thoroughly tested. We hope this is done soon. Because one has not seen an allergic or other reaction when using such pigments does not justify the rights to toss these ingredients into a cosmetic product. Until thorough testing has been done and the results published a reputable cosmetic company should avoid ANY pigment or ingredient that is not on the approved list of ingredients. I can assure you three things.... 1) if the pigments fail any testing we as a manufacturer will avoid them in our products, 2) if the pigments become officially approved we would work to offer fluorescent colors with the approved pigments and 3) until the pigments are documented as approved pigments for use in cosmetics we will assume that they should be avoided. I would challenge any company that uses these pigments to show documentation that the pigments are ACTUALLY APPROVED because we have done a lot of research in this matter and as of this date none are approved.

There is also the question of "glow in the dark" or phosphorescent pigments. These pigments were approved for use by the FDA in the United States (in 2000). To date they have been rejected, however by the European Union. For this reason SNAZAROO does not offer any glow in the dark products.

Our suggestion is to take the conservative side of the issue. If the ingredients are not found safe in both the USA and Europe then you should avoid them. Once approved, you receive a safe go ahead and you can be backed by the product liability of the manufactured (when used properly.)

In the comments above the underscore was added to highlight the key issues.

You choose for yourself what is best for you.

Gary Cole
SNAZAROO USA Inc.
gary@snazaroo.com

Another viewpoint, used with permission by JoJo sent to FPHQ. The text below is cut and pasted below unedited. JoJo does not work for or is not associated with Snazaroo in any way....

This is an informational letter for you to know more about neon paints since we receive a lot of questions about them and we just received new info regarding them. We have been trying for two years to get a straight answer about what the terms “For Hair and Special Effects” and “Not for cosmetic use” really mean. I have heard so many different responses to this, and now we finally have the answer for you. Hold Tight!

These are some things I was told in the past by company officials and also what artists think it means.

“Do not use near the eyes” “Do not use on a regular basis” “It is not a make-up…like foundation. It is special.” “For use under black lights” “Do not use on children” “Do not use on nose, eyes or lips”

“Make your best judgment” “Use them at your own risk” “They are safe and non-toxic, but the FDA makes us put the warning.” “I have never heard any complaints about them in 30 years.” “They may make your eyes burn and water.” “Don’t cover a whole body in them.” and the list goes on…..

Remember, what I am about to tell you is that these “Warnings” have to be put on the labels of any Neon Paint (sold by cosmetic companies) sold in the USA because of the FDA(besides DFX NEON WHITE, NEON BLUE and NEON VIOLET that are made with FDA approved ingredients to be used in cosmetics). The EU also is in a similar situation, but we haven’t done all the research on that yet.

We want to let you read the links on the DFX EU website (since DFX is the only company with some kind of warning about neons on their shopping sites) and see what they say about Neons. We notified them last year about them not putting up proper warnings on their site, and for not properly labeling all neon containers (especially rainbow

cakes) because they were still referring to them as make-up and some lacked the warnings above. They made changes after our request, but we still think the first link is VERY confusing. They are mixing black light approval with glow in the dark paint approval in such a way that I didn’t know what to think was approved by the FDA. The second link is much more clear. We are still working with them on this.

Read their posts for yourself by following these links. Let me know what you think about them.

TAG just added the warning to the neon labels, but the ingredients list on the labels is not complete and we are working with them on that too. They also have no warnings about neon paints on their websites. I am not sure if neons can be used as cosmetics in AU. Let’s find out!

Kryolan has had the “For Hair and Special Effects” and “Not for Cosmetic Use” warning for decades. I called Kryolan SF, and after some coaxing, the employee told me what “Not for Cosmetic Use” really means (“Well, honestly, it is not designed for use on skin.”), and also said that they do not sell the Neons on their site because it is an international site and they are not allowed to sell them in Europe.

Because of this, you cannot find any information about their neon paints on their site, which is why we called them in the first place.

According to him, if you are in the U.S. you have to order Kryolan from independent vendors….the company will not sell them directly to the public.

Wolfe FX will not answer our e-mails about what ingredients are in the neons to make them “not a cosmetic” and also have no warning on their website about neons.

Legally, we can’t give out exact percentages of what is in DFX “face paint” but we can tell you that the regular neons (Magenta, Pink, Orange, Yellow, and Green) contain a high level of Formaldehyde, which is well above the level suggested by the FDA to be use in cosmetics (the suggested level is 0.2% of the total ingredients). The FDA also says that if the Formaldehyde level is under 0.2% the product can be declared “Formaldehyde free”, otherwise, as any other ingredient, it should be listed on the label.

We have not gotten an ingredient list from the other brands, but when we do we will let you know what they are. The other brands do have the same warnings on their labels, so something in them is not intended for cosmetic use.

Special Effects= a term not defined by the FDA (FDA regulations required that warnings on labels should be easy to understand by the regular customers buying the product, so, if we can’t understand what Special Effects means, then this IS NOT proper labeling).

We also found info about Formaldehyde at the HAZMAP website (Occupational Exposure to Hazardous Agents). Read it too please!

Luckily, we do not work in a factory that creates neon paints, nor do we eat them or, hopefully, we don’t wear them on a regular basis.

My concern is that by using the regular neon paints on customers (this goes for DFX, TAG, WOLFE FX and KRYOLAN neons ) we are using a product that is not intended for use on skin according to the FDA recommendations, and this will likely cause legal trouble if a customer has an allergic reaction or finds out that we are using them and decides to do something about it.

Also, if we DO wear neon paints to go to gigs it is possible that frequent use might be bad for our health. Formaldehyde is linked to cancer and some people are highly sensitive to it. From what I understand, there have been no studies, made by independent agencies, on frequent use of neon paints on skin to determine long term health effects, so I can’t tell you what you should or shouldn’t do, and what the consequence might be (DFX claims that their neon products have been tested by a highly recognized dermatologist for skin tolerance, but we don’t know how independent this source is, and if skin tolerance it is the only thing that matters related to neons). Like most of the companies say “They have been in the industry for years and there have been no negative reports.” But that doesn’t mean that there haven’t been any negative things that have happened long term and were never linked to the paint, or that just because it wasn’t reported means that it didn’t happen. It could or could not be true.

The links are provided to let you know what the FDA and other independent agencies say, and you can make your own decisions.

What am I going to do with this new info?I am making the choice not to use them on my face very often, and I will keep them away from my mucus membranes. For legal reasons, I am going to stop using them on people under 18, and those that are over18 will get a full proper warning and have to sign a waiver if they want to get painted with the regular neons.

There are other choices! If you use neons for their bright effect under regular light only, I know that there are other bright colors that kids will love that you can replace them with. I love combining DFX yellow, lite green, lite blue and lite pink or Metallix Fushia Pink to get an almost neon look. Also, Paradise Mango and Wild Orchid make a magical bright effect when combined! You can also use the DFX neon white,blue and violet for your black light gigs.

The U.S. still allows the use and sale of cigarettes, but the warnings have to be loud and clear. In my opinion the warnings above have not been clear enough, and the makeup industry shows the products beings used all over the face and body, which I think is misleading…To me it says “Don’t worry, they are safe”. And they may be safe in general, but they should also be direct and say, these are not for use on skin according to the FDA recommendations. What do you think?

We have to admit that, since we didn’t know exactly what the warning meant, we have posted in the past black light photos on our body painting sites…and I even used a neon rainbow cake in my last book, but I DID put a warning in the book about what the neon labels say, and that any other rainbow cake will work just as well. Now that I know what “not for use as a cosmetic means” I will also put this warning on my blog post about black light body painting. I want to do my best to not promote neon paint use without giving proper warnings.

We have had the Label Warnings posted next to the neon products for sale on our site for over a year. We continued to update the warning as we got more information from the manufacturers and other time consuming research.

We didn’t know about the contents of the paints because they did not put them all on the label (this is also against the FDA regulations) but now that we do know, we are giving our customers a fair warning as you can see on our website. http://www.jestpaint.com/servlet/the-Diamond-FX-cln-Neon-Colors/Categories

What Gary Cole Say’s About Neons, and now I believe. Hit control F to search for his discussion on formaldehyde:

If you live in the U.S.A and come across stores that are selling Neon Paints and they do not have a warning on the site next to the neon items you want to buy, it might be a good idea to send them a letter and request that they change their product descriptions. In no way should a store refer to a regular neon products as make-up or sell them to you without telling you that they are not intended to be used as cosmetics. Also, if you are in the mood, let the manufacturers know that you are disappointed that they do not have labels that contain all the FDA color codes and ingredients and easy to understand warnings about the intended use of the products.

People trust us with their skin and their health when we paint their faces, count on us to add happiness to their day. We all need to be responsible professionals. Just because a color looks great doesn’t mean we should use it without looking at it carefully. Use the neons on hair if you want to take the safe route and not just throw them away.

Santi and I own JestPaint.com, but we are not going to look the other way so that we can continue to make money selling neon paints to uninformed customers. Please give us your honest feedback on this letter. If you see any errors, please let us know.