Listing Colour Additives and Pigments on a CNF

Colour additives trip up more first-time filers than almost anything else on the CNF, mostly because the naming conventions look nothing like the rest of your ingredient list. A pressed eyeshadow with six micas and two iron oxides is not hard to formulate, but it is genuinely fiddly to declare correctly.

Why colourants are named differently

Most of your formula gets listed by INCI name, the same standardized naming system used worldwide. Aqua for water, Glycerin for glycerin, and so on. Colour additives frequently carry a Colour Index number, commonly written as a CI number, alongside or instead of a conventional INCI name. Titanium dioxide, for example, is both an INCI name and a common colourant, and depending on the source ingredient you are using, you may see it referenced with a CI designation too.

The practical point is this: when you are filling in the ingredient section of your Cosmetic Notification Form, you need to identify each colourant using the naming convention that actually matches what the Cosmetic Ingredient Hotlist and Health Canada's system expect, not just whatever appeared on your supplier's product sheet. If your supplier's spec sheet lists a pigment blend under a trade name, you still need to trace it back to its individual colourant components before you file, exactly the way you would with any other supplier blend.

Common colourants and what to watch for

Colourant type	Typical use	What to check
Iron oxides (red, yellow, black)	Foundations, blush, soap colouring	Generally well tolerated, confirm correct CI reference
Titanium dioxide	Whitening, sunscreen physical filter	If used for UV protection, product may cross into drug territory
Mica	Shimmer, pearlescent effect	Confirm source and any coating additives used with it
Ultramarines	Blues and violets in cosmetics	Check current Hotlist status before use
Synthetic organic dyes (FD&C/D&C types)	Lip products, nail products	Some are restricted to specific product categories
Chromium oxide greens	Eye products, soap colouring	Confirm category-specific restrictions

Two things matter more than the exact colour you picked. First, some colourants are restricted to certain categories of product, meaning a dye acceptable in a nail polish is not automatically acceptable in a lip product, because ingestion risk changes the calculus entirely. Second, some colourants come with purity or impurity conditions attached, which is a level of detail easy to miss if you are only checking the ingredient name and not the specific condition attached to its Hotlist entry.

Titanium dioxide is its own special case

Titanium dioxide deserves its own callout because it does double duty. As a cosmetic colourant, it is a routine ingredient in foundations and powders. As a UV filter used for sun protection, it functions as an active ingredient in a fundamentally different regulatory category. If your product's colourant is also doing sunscreen work and you are making an SPF claim, you have likely moved into drug territory rather than cosmetic territory, and that changes your entire filing pathway. Keep the function you are actually claiming clearly separate from the shade or finish you are describing in marketing copy.

What actually goes on the form

When you get to the ingredient declaration on your CNF, list each colour additive the way you would any other ingredient, with its correct name and its concentration or concentration range in the finished product. If you are using a proprietary pigment dispersion, expand it into its real components the same way you would expand a preservative blend, multiplying the pigment's percentage in the dispersion by the dispersion's use level in your product. Do not file the trade name of the dispersion as if it were a single ingredient.

A quick pre-filing pass

Before you submit, run through your colourants one more time:

• Confirm every colourant maps to a name Health Canada's system will recognize
• Check each one against the current Hotlist for category restrictions or purity conditions
• Separate any colourant doing double duty as a functional active, especially titanium dioxide and zinc oxide
• Expand any pigment blend or dispersion into its real percentages

This part of a filing is exactly where Cosmetic Comply earns its keep. It maps colourants and pigment blends to the correct names, expands dispersions into real component percentages, and screens each one against the current Hotlist conditions before a reviewer confirms the result and the notification goes out. Colour is often the most fun part of formulating and the most tedious part of filing. It does not have to stay that way.