Children's face paint — HMTc Standard

How every number on this page is set

Category 2 is the child-scoped personal-care category (ages 0-5). Three category-specific rules govern every row and are stated here once.

RULE 1 - THE CHILD ROW IS A FLOOR-PLUS, NEVER A DISCOUNT. Category 13 (adult leave-on cosmetics) and Category 14 (adult rinse-off cosmetics) cover the same product forms for adults. A Category 2 row is never looser than the Category 13/14 row for the same form. Where a sovereign instrument publishes a CHILD-scoped tier, that tier is the applicable cell. Where it publishes an ADULT-market loosening carve-out, Category 2 does not adopt it. Two such carve-outs bind in practice. Germany’s BVL 2017 raises lead from 2.0 to 5.0 mg/kg for make-up powder, rouge, eye shadow, eyeliner, kajal and theatrical, fan or carnival make-up, and raises arsenic from 0.5 to 2.5 mg/kg for theatrical, fan or carnival make-up; Korea’s MFDS raises nickel from 10 to 30 ug/g for colour cosmetics and 35 ug/g for eye make-up. Both carve-outs exist because adult decorative cosmetics carry heavy pigment loads. Neither is a child determination. A children’s face paint or play make-up is applied to a 0-5 child’s face, transferred hand-to-mouth and licked; certifying it at five times the general cosmetic lead limit would be indefensible. Those rows therefore read across the SAME instrument’s general-cosmetic tier, which is stricter, and the refused carve-out is named in the cell so the reader can see exactly what was declined and why. This is over-compliance against a real sovereign number, not an invented one; Category 16 (Supplements, live) set the same precedent by applying the strictest child-protective limit across an entire category.

RULE 2 - THE INGESTION-ADJACENT ORAL FORMS TAKE THE SWALLOWED-PRODUCT TIER. Germany’s BVL 2017 is the only instrument in the register that publishes a separate, stricter TOOTHPASTE tier (lead 0.5 mg/kg against 2.0 mg/kg general). That tier exists because toothpaste sits on the oral mucosa and is partly swallowed. Children’s toothpaste binds it directly. Children’s lip balm reads across it: a lip product on a 0-5 child is applied to the vermilion border, contacts the oral mucosa and is swallowed at a fraction at least comparable to toothpaste, and the swallowed-product tier is the nearest sovereign cell for that pathway. Category 15 (Feminine Care, live) established this read-across pattern by taking the BVL toothpaste tier onto mucosal-contact products. Face paint, children’s make-up and nail polish do NOT take the toothpaste tier: hand-to-mouth transfer from those forms is incidental contamination, not the product’s designed contact surface, and stretching an oral-mucosal tier onto skin-applied decorative cosmetics would be a distinction the instrument does not draw.

RULE 3 - THE MINERAL SPLITS ARE REAL BUT THEY DO NOT MOVE THE NUMBER. The taxonomy splits four pairs on mineral content: cornstarch versus talc baby powder, chemical versus mineral baby sunscreen, non-ZnO versus ZnO diaper cream, and plain versus mineral-bearing children’s lip balm. The split is correct: talc, zinc oxide, titanium dioxide, mica and iron oxides are the raw materials that carry the metal load, so the two halves of each pair have entirely different contamination risk profiles and must be sampled and qualified differently. But the split does NOT produce two different sovereign numbers, and this standard does not manufacture one. The only mineral-specific tiers in the register are LOOSENINGS: the EAEU TR CU 009/2011 tier for perfumery-cosmetic products containing more than 1% natural plant or natural mineral raw material sets lead at 5.0 mg/kg, arsenic at 5.0 mg/kg and mercury at 1.0 mg/kg, and Korea’s MFDS raises lead to 50 ug/g for powder products using clay as a raw material. Every one of those values is looser than the general cosmetic tier this standard binds, and none is adopted for a 0-5 product. The mineral rows therefore bind the same ceilings as their clean counterparts, which makes them harder to meet, which is the intended and honest outcome. What the mineral rows add is a raw-material qualification obligation carried in the row’s scope note, not a different number.

WHAT THE REGISTER DOES NOT SUPPORT. Five of the eleven panel cells have no sovereign finished-cosmetic maximum anywhere in the register and are published as CONTROLS rather than as invented ceilings: inorganic arsenic (no jurisdiction speciates arsenic in a cosmetic; bounded by the binding total-arsenic ceiling), tin, aluminium, total chromium and hexavalent chromium. The only hexavalent-chromium number in the cosmetic instrument family is EU REACH entry 2020/2081 at 500 ug/kg, which is scoped to mixtures injected intradermally for tattooing and permanent make-up - a different exposure route, a different product class and a different risk basis - and it is not read across onto surface-applied children’s cosmetics. The only total-chromium, tin and aluminium numbers are EU Toy Safety Directive 2009/48 and ASTM F963 element-MIGRATION limits, which are numerically incomparable to a total-content cosmetic limit. Control is the correct fail-safe for all five: testing is mandatory, the analytical method and the escalation rule are published, and no ceiling is fabricated.

REGISTER GAP OF RECORD. Sri Lanka SLS 187:2025 is the only CHILD-scoped cosmetic instrument in the register (skin powder for children, talc-base and starch-base). Every one of its rows carries status ‘draft guidance; not for implementation’ and is gated out by the compiler, so it anchors nothing here. Its published values (lead 10 mg/kg, cadmium 3 mg/kg, arsenic 1.5 mg/kg, mercury 1 mg/kg) are in every case LOOSER than the German BVL general-cosmetic tier this standard binds, so no protection is lost by its exclusion; it is recorded as a register gap for verified re-ingest, not as a missed stricter anchor. The US FDA draft cosmetic lead guidance (10 mg/kg) is gated for the same reason and is likewise looser.

Master Limit Table

All values in ppb (µg/kg), as-sold basis. 5 of 11 analytes carry a firm ceiling; the remainder are governed by mandatory control or reflex-speciation screening with no standalone number, itemised in the derivation below. A brand meeting every firm value on a like-for-like basis, and passing every control, qualifies for the mark.

Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Cr-VI, Ni, Sn, Al, Cr) carry a 150% transitional allowance under the program’s Status A–E framework.

Derivation — every government’s number, side by side

The full derivation for Children's face paint. Each row lists every government maximum level in force worldwide, converted to the as-sold basis; the HMTc limit is the strictest of them, and the last column names which sovereign law binds. A blank cell means that government sets no limit for this analyte in this product.

All values µg/kg (ppb), as-sold basis. ² no government regulates this analyte for this exact product form: the value is a disclosed read-across from the nearest applicable government maximum, and the derivation names the instrument it comes from. It is never taken from occurrence data. After publication the standards ratchet may tighten it, using certified-lot results only. ³ not material in this matrix: controlled by reflex speciation or packaging control, not a standalone number. &sup4; no sovereign maximum exists for this analyte in this product, but a credible exposure pathway does — it is screened on every lot under ALARA against the tightest analogous reference, not assigned an invented number.

Occurrence and derivation rationale

For each analyte on the panel: what the peer-reviewed and survey literature measured in this category, cited one way to the Heavy Metal Index, and the Method v2.0 reasoning behind the certification limit — including, where no government sets a number, why the program sets one anyway. Occurrence figures are literature findings; the derivation is the certifier's.

Cite this standard

Pendergrass, K. “Children's face paint.” In Heavy Metal Tested & Certified (HMTc) Infant and Child Personal Care (Ages 0-5) standard, version 1.0. Institute of Contaminant Standards (ICS), 2026. DOI: registration pending.

The literature baseline for every analyte is maintained independently at the Heavy Metal Index. This certification standard applies those findings; the two are kept editorially separate by design.