The statute

The review you cannot read off a page

On this page11

What the standard actually requires Which is why the conformance statement is a claim The criteria are documented So the file is part of the obligation What a repackager is buying And the second is cheaper when it is available Mixing moves you off that route What it is not Where a container supplier fits The order to do it in References

Everything else here can be settled from a document. This cannot.

What the standard actually requires

That the formulation be reviewed against the criteria in the standard by somebody qualified to do it, and that the label report what the review found. The label is an output and this is the input.

Which is why the conformance statement is a claim

"Conforms to ASTM D-4236" says a review happened and the labeling follows it. There is no version of that sentence that is true without the review behind it.

The criteria are documented

Subsection (b)(3) requires producers to describe the criteria used to determine whether a material has the potential for producing chronic adverse health effects and to submit them to the Commission, and (b)(4) requires formulations and criteria on the Commission's request.

So the file is part of the obligation

Not just the printed label. Being able to produce the criteria and the formulation on request is in the statute, which makes record keeping a requirement rather than good practice.

What a repackager is buying

Either a review of their own product, or a documented position from the producer's reviewer that the existing determination carries to the repackaged form. One of those two, in writing.

And the second is cheaper when it is available

Which is the practical reason to ask the producer first. A reviewer who has already looked at the formulation is in the best position to say whether splitting it changes anything.

Mixing moves you off that route

A wash blended from three things is a formulation nobody has reviewed. That is the point at which the repackager question becomes a producer question and the answer costs more.

What it is not

It is not a safety data sheet, which serves a different purpose under different rules, and it is not a supplier's assurance that a material is safe. Those are useful inputs to a review and they are not the review.

Where a container supplier fits

Nowhere in the review and squarely in what follows it: how much label surface the bottle has, whether an insert is needed, and what the resin will tolerate. That is the part this catalog can answer.

The order to do it in

Review, then label, then container, then production. Picking the bottle first is the common order and it is how a 15 mL dropper ends up holding a product whose label does not fit on 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

16 CFR 1500.14(b)(8), the art materials labeling requirements. The label carries a signal word, "WARNING" where only chronic hazards exist, "prominently visible and set in bold capitals in a size equal to or greater than the statement of potential chronic hazards"; the potential chronic effects; every component and known decomposition product of the formulation with a potential for chronic hazards, "listed prominently"; safe handling instructions; sensitizing components; and a statement of conformance in one of three permitted forms, "Conforms to ASTM Practice D-4236", "Conforms to ASTM D-4236" or "Conforms to the health requirements of ASTM D-4236", which "should appear whenever practical on the product". 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.