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All Containers›Shop by use case›Paint and ink›Art materials law›The conformance statementShop all paint and ink →
Art materials law

The conformance statement

By Dwight Davis, Founder

Updated

On this page8
A short sentence with exact permitted forms and a specific list of places it can go.

The three wordings

"Conforms to ASTM Practice D-4236", or "Conforms to ASTM D-4236", or "Conforms to the health requirements of ASTM D-4236". The rule gives those three and says the statement may be combined with other conformance statements.

Where it should go

It should appear on the product wherever practical. The rule then names the alternatives: the individual product package, a display or sign at the point of purchase, separate explanatory literature available at the point of purchase, or a response to a formal request for bid or proposal.

Which matters for very small packages

A 30 ml ink bottle has little room, and the rule anticipates that by allowing the statement elsewhere. That is a genuine flexibility and it is why the phrase "wherever practical" is in there.

It is a statement about process, not safety

Conforming to D-4236 means the formulation went to a toxicologist and the labeling follows from the advice. It does not assert that the product is harmless, and reading it that way is the common misunderstanding among buyers.

Certifying organizations are optional

The rule notes that manufacturers or repackagers may wish to have compliance certified by a certifying organization and gives guidelines for one. A certification mark is therefore a private seal on top of a legal obligation, not a substitute for it.

Do not put it on something unreviewed

The statement asserts that a process happened. Printing it because competitors do, on a product no toxicologist has seen, is a false statement of conformance rather than a stylistic choice.

And revisit it on reformulation

If a producer or repackager reformulates, the new formulation must be evaluated and labeled in accordance with the standard. The conformance statement carries forward only if the review did.

References

16 CFR 1500.14(b)(8)(i)(C)(7), the statement of conformance: "Conforms to ASTM Practice D-4236", "Conforms to ASTM D-4236", or "Conforms to the health requirements of ASTM D-4236". It should appear on the product wherever practical, and may otherwise sit on the individual package, a point-of-purchase display or sign, separate explanatory literature, or a response to a formal request for bid. 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.