How Colorant Rules Shape a Makeup Notification

Formulating a foundation or an eyeshadow palette involves a different kind of ingredient scrutiny than a body lotion, mostly because of the colorants doing the heavy lifting. Pigments in makeup often carry their own set of conditions on the Cosmetic Ingredient Hotlist, tied specifically to where on the body the product is meant to be used, and getting that mapped correctly is a real part of preparing an accurate notification.

CI numbers are how colorants get identified

Colour Index (CI) numbers are the standard way pigments and dyes get identified in cosmetics, similar in spirit to how INCI names standardize other ingredients. A colorant might have a common name on your supplier's label, but the CI number is what actually pins down which specific compound you're using, and it's the number a reviewer or the Hotlist itself will reference.

Some common examples in makeup:

Common use	Example CI reference style	Typical function
Red pigment	CI 15850	Colorant in lip and cheek products
Iron oxide (black)	CI 77499	Colorant, widely used across makeup
Iron oxide (yellow)	CI 77492	Colorant
Titanium dioxide (white/opacifier)	CI 77891	Colorant, opacifier, also a UV filter in some uses

Always confirm the exact CI number against your specific pigment supplier's documentation rather than assuming a common shade name maps to a fixed number, since formulations and blends can vary.

Why area of use matters so much here

This is the detail that trips up makeup formulators specifically. Some colorants permitted for use on lips are restricted or excluded for use near the eye, and the reverse can be true too. The Hotlist attaches these area-of-use conditions because different areas of the body carry different sensitivity and exposure considerations, mucous membrane contact for lip products, proximity to the eye for eyeshadow and mascara.

Practical implication: the exact same pigment might be fine in your blush formula and restricted in your eyeshadow formula. You can't check a colorant once and assume it clears every product in your line. Each area of use needs its own check against the current Hotlist.

Building your colorant declaration

For each shade in a makeup line, whether it's a single foundation shade or a twelve-pan eyeshadow palette, you need to document:

1. The specific colorant used, by CI number, not just a shade name like "warm bronze"
2. The percentage or range of that colorant in the finished product
3. The product's area of use (lips, eyes, face, etc.)
4. Whether the Hotlist attaches any area-specific restriction to that colorant

For a multi-shade line, this means repeating the process per shade, since different shades in the same palette often use different pigment blends even if they're marketed under one product name.

A common real-world snag

Eyeshadow palettes are the most likely place this becomes a genuine headache, because a single palette might use six or eight different pigments across the pans, several of them overlapping between shades at different ratios. It's easy to check the first two shades carefully and then get looser about the rest, assuming "it's the same base formula." If the pigment blend actually differs shade to shade, and it usually does since that's what creates different colours, each shade needs its own check.

Mica and iron oxide blends are common in these formulas and are broadly used, but "broadly used" isn't the same as "cleared for every area of use in every combination," so don't skip the check just because a pigment feels familiar.

Getting through this without missing something

The practical challenge with a colour-heavy makeup line isn't usually that any single colorant is exotic or hard to find information on. It's the volume of individual checks needed once you're covering multiple shades, each with its own pigment blend, each needing an area-of-use check against the current Hotlist. Cosmetic Comply is built to take a full formula, including every colorant by CI number, and screen it against Canada's restricted and prohibited lists with the area of use factored in, then have a real reviewer confirm the result before your notification goes out. For a shade-heavy makeup line, that's often the difference between a straightforward filing and a lot of manual cross-referencing per pan.