Getting started

From bulk to bottle

Updated October 2026

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One: are you a producer or repackager of art materials?Two: get the formulation to a toxicologist Three: write down your criteria, and file them Four: choose the container for the chemistry Five: build the label from the rule Then diarize the five years Keep the whole file together References

Five decisions, and the first one is a question about who you are rather than about the product.

One: are you a producer or repackager of art materials?

If you market or represent the substance as suitable for use in creating visual or graphic art, and you package it in sizes for individual users or a small group, then yes. Both halves have to be true and both are within your control.

Two: get the formulation to a toxicologist

The producer or repackager shall submit art material product formulations or reformulations to a toxicologist for review, and the toxicologist is required to keep them confidential. If you are repackaging, that means getting the formulation from your supplier.

Three: write down your criteria, and file them

Each producer or repackager shall describe in writing the criteria used to determine whether an art material has the potential for producing chronic adverse health effects, and submit that description and a list of the materials needing warnings to the Commission.

Four: choose the container for the chemistry

Solvent-borne, alcohol-borne and water-borne products make very different demands, and 149 of the 191 containers on this shelf are HDPE with 42 in glass. This is the point at which the resin question gets settled.

Five: build the label from the rule

Signal word, chronic hazards in descending severity, the hazardous components named, handling instructions, sensitizers, the conformance statement, and where chronic labeling applies a US address, a telephone number and a statement that it is inappropriate for children.

Then diarize the five years

A toxicologist must review formulations and labels as necessary but at least every five years. That is a calendar item with a regulation behind it, and it is the obligation most likely to be forgotten because nothing prompts it.

Keep the whole file together

Formulation, toxicologist opinion, written criteria, filed submission, label artwork and the review date. Every one of those is referenced by the others, and a reformulation puts all of them back in play at once.

References

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

16 CFR 1500.14(b)(8)(ii)(C), (D) and (E): describe the criteria used in writing and submit that description and a list of art materials needing hazard warnings to the Commission’s Division of Regulatory Management; carry the US name, address and telephone number and a statement that the material is inappropriate for use by children where chronic labeling applies; and get new hazard information onto labels within 12 months of discovery. law.cornell.edu

16 CFR 1500.14(b)(8)(i)(E), (F) and (G), on labeling practices: the signal word WARNING in bold capitals at least as large as the chronic hazard statement, chronic hazards grouped in descending severity, chronically hazardous components named prominently, safe handling instructions, and a list of sensitizing components. 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.