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Updated October 2026

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What this covers The rule is a standard that Congress made law It names the repackager And the trigger is the package size Which makes this a packaging property, not a chemistry one What it obliges, in short Two things the rule excludes References

The question is not whether you made the paint. It is what size bottle you put it in.

What this covers

Acrylic and oil paint, watercolor, fabric paint, alcohol and calligraphy ink, pouring medium and screen ink. All of them liquids poured into a bottle, and all of them art materials in the sense a federal regulation uses the term.

The rule is a standard that Congress made law

The Labeling of Hazardous Art Materials Act provided that the requirements of ASTM D-4236 shall be deemed a regulation issued by the Commission under the Federal Hazardous Substances Act, effective November 18, 1990. The Commission reproduces the whole standard at 16 CFR 1500.14(b)(8).

It names the repackager

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 a work of visual or graphic art. Decanting somebody else’s medium into your own bottles puts you inside that definition.

And the trigger is the package size

The standard applies exclusively to art materials packaged in sizes intended for individual users of any age or those participating in a small group. So the act of packaging down from bulk is precisely what brings the rule into play.

Which makes this a packaging property, not a chemistry one

Nowhere else in this library does the decision to use a smaller bottle change which law applies. It is worth understanding before the first case of bottles is ordered rather than after.

What it obliges, in short

A toxicologist review of the formulation, precautionary labeling in a specified form where chronic hazards exist, a route for poison control centers to get formulation information, a written statement of your criteria filed with the Commission, and re-review at least every five years.

Two things the rule excludes

Economic poisons under FIFRA, and drugs, devices and cosmetics under the FDCA. So a pigment marketed as a colorant for soap or makeup is outside this rule and inside a different one, and the marketing decides which.

References

16 CFR 1500.14(b)(8), which reproduces ASTM D-4236 as a regulation under the Labeling of Hazardous Art Materials Act, 15 U.S.C. 1277, effective November 18, 1990. Paragraph (b)(8)(i)(A)(2) limits it to art materials packaged in sizes intended for individual users or a small group; (b)(8)(ii)(A) defines art material by what the producer or repackager markets it as, and excludes FIFRA economic poisons and FDCA drugs, devices and cosmetics. law.cornell.edu

16 CFR 1500.14(b)(8)(i)(C) and (D), on the producer or repackager’s duties: submit the formulation to a toxicologist, supply a poison exposure management information source or a 24-hour cost-free telephone number to poison control centers, and have formulations and labels re-reviewed at least every 5 years. Paragraph (D) lists the seven matters the toxicologist must take into account. law.cornell.edu

Written from federal regulation and from measured catalog data, not from a formulation bench. Whether a specific product needs chronic hazard labeling is a toxicologist’s determination and the rule says so; nothing here substitutes for that review. Anything on these pages is a starting point.