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Art materials

What LHAMA requires

On this page9
The labeling requirements of ASTM D-4236 are a Commission regulation, effective 18 November 1990, not an industry standard you may adopt.

What the regulation does

16 CFR 1500.14(b)(8) takes the labeling requirements of ASTM D-4236 and deems them a Commission regulation. A failure to meet them is a labeling violation under the Federal Hazardous Substances Act rather than a departure from a voluntary practice.

The first obligation is review, not wording

The producer or repackager shall submit the product formulation, or any reformulation, to a toxicologist for review. That is the operative sentence, and it means the compliance work begins before any label exists.

What the toxicologist is reviewing for

Chronic health hazards, and what precautionary labeling the product should carry as a result. The determination rests on generally accepted, well-established evidence, which is a stated standard rather than a matter of professional taste.

Reformulation restarts it

The regulation names reformulations explicitly. Changing a solvent, a resin or a preservative is a new formulation to be reviewed, and a label that carried a conformance statement for the old formula does not carry it for the new one.

Then the labeling

Where chronic hazards are present the label carries the signal word, the hazard statements drawn from the regulation, the names of the chronically hazardous components, safe handling precautions and a source of further health information.

And the conformance statement

One of three exact forms: "Conforms to ASTM Practice D-4236", "Conforms to ASTM D-4236", or "Conforms to the health requirements of ASTM D-4236". A paraphrase is not one of them.

Which of these six products it reaches

An art material is defined by use rather than by chemistry, so the same glue can be inside or outside depending on who it is sold to and for what. A decoupage medium is squarely a craft material; a construction adhesive sold to trade is a different question. That boundary is one to put to the toxicologist along with the formula.

The practical sequence

Formula, then review, then the toxicologist’s recommended labeling, then the artwork, then the container that can carry the artwork. Running that in reverse is how a product sits finished in a warehouse waiting for a review nobody started.

References

16 CFR 1500.14(b)(8), the art materials provision implementing the Labeling of Hazardous Art Materials Act. It makes the labeling requirements of ASTM D-4236 a Commission regulation, effective 18 November 1990, requires that "the producer or repackager of art materials shall submit art material product formulation(s) or reformulation(s) to a toxicologist for review", and sets the conformance statements a compliant label carries. law.cornell.edu
Written from 16 CFR 1500.14(b)(8), 1500.121 and 1700.14, and from the catalog as it stood on 17 October 2026. Whether a particular product is an art material, what its chronic hazard labeling should say, and whether its closure must be child resistant are determinations about a specific formula; the first of those is a question for a toxicologist by regulation, and nothing here substitutes for one.