Friday, October 10, 2014

UV/Neon/Glow in the Dark


We get a lot of phone calls from customers with questions about Neon and Glow in the Dark face 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 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. 

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 face paint company calls their paints Neon, or UV, or DayGlow or Fluor they are referring to the same property: they glow under black light. DayGlow and most UV paints also have a noticeable brightness under sun light as well. 


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 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. 

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 cosmetic.

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 have conducted their own tests in 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, but they do provide a level of security when deciding to use the product, or not.

To get around compliance issues, 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. This has been in effect for over 30 years.

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

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. 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 as well as Mehron, in their Fantasy FX line and B.L.A.M.E pens and B.L.A.M.E liquid colors.

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.


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

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, but some do comply with EU cosmetic regulations.

Mehron, Ruby Red and Kryolan all produced an FDA compliant glow in the dark paint.
It is worth mentioning that all the of brands we import go through the FDA when they arrive to the country, and they check for labeling compliance. 

Many times, like it happens with Henna, or real Tattoo inks, the FDA is very aware of the use of the product and know that it is in violation of their regulations, but since they do not consider it a hazard (because they haven’t received many complaints about bad reactions) 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.

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 companies using them 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. It is also 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. Others have in their language that they require FDA compliant products to be used.


                    We get signed waivers when we use Neon Paints, informing the customer before we use them, and letting them choose. 

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 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.



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.

Image courtesy of Idea go / FreeDigitalPhotos.net

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