The check, before the first shade ships
Updated
On this page9
One: for every colorant, which listing and which uses?
Part 73, 74 or 82, recorded by regulation number with the permitted uses beside it. "Cosmetic grade" is not a defined term and will not answer this. Get the citation from the supplier.
Two: is any application inside the area of the eye?
Using the regulation’s definition: the orbital region between the supra-orbital and infra-orbital ridges, including the eyebrow, the skin below it, the lids, the lashes and the soft tissue under the eye. Brow and under-eye products are inside.
Three: which declaration form are you using?
Strict descending order, or the permitted grouping with colors last and unordered. If a shade range shares a declaration, check all four conditions of the "may contain" route, including that no non-common brand designation appears.
Four: is the safety substantiated, per shade?
Each ingredient and each finished product, before marketing. A new shade is a new finished product for this purpose. The alternative is a conspicuous warning that the safety has not been determined.
Five: does the format exist?
Loose powder in a jar, with the single 43 mm sifter disc if the neck matches. An emulsion in one of the 9 airless pumps. A pressed pan, a palette, a mascara or a brow wand is not available from this catalog.
And fill by weight
Because static makes a fine pigment settle unpredictably, so a volumetric fill gives inconsistent declared quantities across a run and across shades of different density.
File it per shade
Colorant listings and uses, the eye-area determination, the declaration form, the substantiation entry and the container. Adding a shade adds a row, and that is the step that catches the range extension failure.
Two of the five are per shade, so this is a table
The colorant listings and the eye-area determination have to be answered for every shade, which makes the compliance record a row per shade rather than a document per product. The row added last is the one nobody fills in.