FD&C and D&C Dyes: How Canada Handles Cosmetic Colorants

Colorants are one of the few ingredient categories where the naming conventions genuinely stack on top of each other, US drug and cosmetic terminology, an international color index system, and Canada's own permitted list, all describing the same handful of dyes. It's confusing the first time you look at a supplier spec sheet and see a name like "FD&C Red No. 40" sitting next to "CI 16035."

Where FD&C and D&C names come from

FD&C and D&C are US labeling conventions, not Canadian ones. FD&C stands for dyes approved for use in Food, Drug, and Cosmetics, while D&C denotes dyes approved for Drug and Cosmetics only, not food. You'll see these names constantly on supplier documentation because so much of the global colorant supply chain sells into the US market and labels accordingly.

The important thing for a Canadian filer is that these US-style names are not what goes on your Cosmetic Notification Form. They're a useful cross-reference for identifying which dye you're actually dealing with, but the filing itself needs the colorant identified properly by its recognized naming, typically tied to its Colour Index, or CI, number.

CI numbers: the actual identifier that matters

The Colour Index system assigns a unique numeric code to each colorant, synthetic or natural, regardless of which country's cosmetic or food naming convention a supplier happens to use on their spec sheet. CI 16035, for example, is the same dye that US paperwork calls FD&C Red No. 40. Once you have the correct CI number, you can confirm the dye's actual identity independent of whatever trade or regional name a supplier attached to it.

Common name style	Type	Identifier to confirm
FD&C Red No. 40	Food, Drug, Cosmetic approved (US convention)	CI number
D&C Red No. 7	Drug, Cosmetic only (US convention)	CI number
FD&C Blue No. 1	Food, Drug, Cosmetic approved (US convention)	CI number

On an ingredient list, colorants are conventionally shown using their CI number, often written as "CI" followed by the five-digit code, and they're typically grouped at the end of the ingredient declaration regardless of their actual concentration in the formula.

Why you can't just trust the supplier's name

A supplier data sheet built for the US market will often lean entirely on FD&C or D&C naming because that's what their US customers expect to see. If you take that name at face value and put "FD&C Red No. 40" directly onto a Canadian filing without cross-referencing it to the correct CI number and confirming its permitted status in Canada specifically, you're skipping the actual verification step. US approval status and Canadian permitted status are two separate regulatory determinations, even when the underlying dye happens to be the same molecule.

Confirming permitted status before you notify

Colorants, like any other cosmetic ingredient, can appear on the Cosmetic Ingredient Hotlist as prohibited or restricted to specific conditions of use, concentration, or product category. Some colorants permitted for certain product types may be restricted for others, for instance around the eye area, where a stricter standard is common across most markets due to the sensitivity of that application site.

Before finalizing a formula that includes a synthetic dye:

1. Identify the dye's CI number from the supplier's technical documentation, not just its FD&C or D&C trade name.
2. Check the Cosmetic Ingredient Hotlist for that colorant's current status in Canada.
3. Confirm whether any restriction is product-category specific, such as a different standard for eye area products versus general skin or hair use.
4. Note the colorant on your CNF using its correct identifier and concentration.

A practical note on natural colorants too

Not every colorant is a synthetic FD&C or D&C style dye. Mica, iron oxides, and various plant-derived colorants show up constantly in indie cosmetics and soap, and they carry their own INCI names and their own Hotlist considerations, separate from the synthetic dye framework entirely. Don't assume a colorant is automatically simpler to clear just because it's mineral or plant derived rather than a synthetic dye; treat every colorant, regardless of source, with the same verification step.

Colorant identification is a small but fiddly corner of formulation, exactly the kind of detail that's easy to get slightly wrong when you're working from a supplier sheet built for a different market. Cosmetic Comply resolves colorants to their correct identifiers and checks them against the current Hotlist alongside every other ingredient in your formula, so a dye's US-market name doesn't quietly slip past a Canadian filing unchecked.