2. Technical requirements
Technical Requirements in the EU
In the European Union, the regulation of pigments used for cosmetic applications like Powder Brows falls under Regulation (EC) No 1223/2009 on Cosmetic Products. This regulation mandates a comprehensive safety assessment for all pigments before being marketed. Every component, including colorants, must be listed with their Color Index (CI) numbers. The concentration of heavy metals such as lead, mercury, and arsenic is closely monitored to ensure they remain within permissible limits.
The EU also enforces a strict ban on animal testing for cosmetic products. The traceability of each product batch is vital for effective recall processes and safety concerns. Furthermore, manufacturers and importers need to follow the REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) regulations, which protect human health and the environment by managing the risks associated with chemical substances.
Technical Requirements in the US
The Food and Drug Administration (FDA) oversees pigment regulation for cosmetics under the Federal Food, Drug, and Cosmetic Act in the United States. The FDA's approach requires pre-market approval for some color additives, with each batch undergoing tests for impurities. The labeling of pigments must comprehensively cover all ingredients and potential allergens. The FDA also plays a role in certifying color additives, ensuring they meet safety and quality standards. Manufacturers are expected to adhere to Cosmetic Good Manufacturing Practices (CGMP) to guarantee the safety and quality of the pigments.
Animal Testing in Pigment Manufacturing
The claim that pigments are "not tested on animals" often emerges in the cosmetics industry, including in the field of semi-permanent makeup pigments. Professional artists must understand the context behind such claims, which may not always stem from ethical considerations by the manufacturer. In many instances, the lack of animal testing is due to the extensive pre-existing data on the safety of the colorants and additives used in these pigments.
A notable example is Carbon Black (CI 77266). This substance has undergone multiple animal tests over time, demonstrating its skin safety and minimal irritation potential. In some historical tests, substances were applied to the shaved skin of New Zealand rabbits – ironically, the same animals often depicted in "cruelty-free" product advertisements. In these tests, patches containing the substance were placed on the rabbits' skin for 24 hours, and the substance was also introduced into their eyes to assess irritation levels. While these tests were relatively mild compared to other forms of animal testing in various industries, they highlight the real basis behind certain "cruelty-free" claims.
Therefore, when encountering claims about ethical choices regarding animal testing in pigment production, it's essential to consider the broader context. Often, these claims are more about the minimal need for additional testing due to the well-established safety profiles of the mixed substances rather than purely ethical decisions made by the company. Understanding this distinction is vital for any professional artist who aims to be well-informed and transparent about the products they use in their practice.