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What an art material is

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The definition Which is unusually wide And a repackager is named in it What it excludes Users of any age Because the hazard it addresses is chronic The standard is law, not a voluntary practice Which changes who the question is for This property cannot answer the chemistry What it can do is tell you which questions are live References

Or repackager. Two words in a federal definition that most of this hobby has never read.

The definition

An art material is "any substance marketed or represented by the producer or repackager as suitable for use in any phase of the creation of any work of visual or graphic art of any medium". It is a marketing test rather than a chemistry test: what decides is how the substance is presented.

Which is unusually wide

Any medium, any phase of creation. A thinner, a varnish, a wash medium, a pigment, a texture paste and a basing glue are all art materials when they are sold for making art, whatever else they also are.

And a repackager is named in it

Not implied, not reached by analogy. The word sits in the definition alongside producer, and it appears again in what the label must carry and in the duty to update that label. Somebody who buys bulk paint and sells it in 15 mL bottles is in the definition.

What it excludes

Economic poisons under the Federal Insecticide, Fungicide, and Rodenticide Act, and drugs, devices and cosmetics under the Federal Food, Drug, and Cosmetic Act. Those are regulated elsewhere rather than exempted.

Users of any age

Subsection (b)(2) says the standard "applies to art materials intended for users of any age". So the common assumption that this is a school supply rule and an adult hobby product sits outside it is wrong at the level of the text.

Because the hazard it addresses is chronic

Not a burn or a poisoning but long-term exposure, which does not care how old the user is. That is also why the labeling is a toxicologist's determination rather than a set of thresholds you can look up.

The standard is law, not a voluntary practice

Subsection (a) makes the labeling requirements of ASTM D-4236 "deemed to be a regulation issued by the Commission". Conforming to a consensus standard here is complying with a federal regulation.

Which changes who the question is for

Not only the paint companies. Anybody in this hobby who sells a liquid they did not formulate, in a bottle they chose, under a name they wrote, is in the definition and has a labeling question to answer.

This property cannot answer the chemistry

What goes on the label depends on a review of the formulation by a toxicologist. That is the one step in this area that cannot be done from a document, and no page here substitutes for it.

What it can do is tell you which questions are live

Whether you are a repackager, what the label has to carry, what the small container clause does, and where the flashpoint rules take over from the art materials ones. Those four settle most of it.

References

15 U.S.C. 1277, the Labeling of Hazardous Art Materials Act. Subsection (a) makes the labeling requirements of ASTM D-4236 "deemed to be a regulation issued by the Commission under section 1262(b) of this title". (b)(1) defines an art material as "Any substance marketed or represented by the producer or repackager as suitable for use in any phase of the creation of any work of visual or graphic art of any medium", excluding economic poisons under FIFRA and drugs, devices or cosmetics under the FFDCA. (b)(2) "applies to art materials intended for users of any age". (b)(5) requires the label of an art material needing chronic hazard labeling to carry "the name and address of the producer or repackager of the art materials and an appropriate telephone number and a statement signifying that such art materials are inappropriate for use by children". (b)(6) requires new hazard information to be "incorporated into the labels of such art materials that are manufactured after 12 months from the date of discovery". law.cornell.edu

Written from 15 U.S.C. 1277, 16 CFR 1500.14(b)(8) and 16 CFR 1500.3(c)(6), and from the catalog as it stood on 18 October 2026. Where a requirement turns on a determination the Commission makes rather than on a fixed rule, this property says so. Nothing here is a toxicological review, which is the one thing in this area that cannot be done from a document.