Contents

Highly pigmented, non-skin-tone makeup for theatrical, festival, sporting and costume use. Face paint is a cosmetic in law and is treated as a toy or a novelty by a great many of the people who buy it — and that gap is where the injuries happen.

The formats

Type Base Behaviour
Water-activated cake Wax, soap-based or acrylate binder, in a pan Activated with a damp brush or sponge; the professional standard
Cream / grease paint Oils and waxes Opaque, blendable, slow to set; needs powdering
Alcohol-activated Pigment in an alcohol vehicle Waterproof, used for special effects and film
Liquid / airbrush Water or alcohol + pigment Fine, even coverage; requires equipment

Professional brands built for skin — Mehron, Snazaroo, Kryolan, Ben Nye, Wolfe, Paradise and similar — are formulated and tested as cosmetics. Craft paint, poster paint, acrylic and tempera are not cosmetics and must never go on skin, regardless of a "non-toxic" mark, which refers to ingestion in art materials and says nothing about dermal use.

The pigment problem

This is the category's defining regulatory issue, and it is worth understanding precisely.

In the US, colour additives are the one part of cosmetic law with genuine premarket control: an additive may be used only if FDA has approved it for that use, and certified colours must come from FDA-certified batches. The permitted palette for cosmetics is narrower than the palette available to industrial and artists' colours, and it is narrower again for the eye area.

Practical consequences:

  • Vivid, saturated colours are harder to make legally than they look, which is why imported novelty face paints repeatedly fail testing.
  • Some pigments legal in a face paint are not legal near the eyes. Products should state whether they are eye-safe.
  • Independent testing of imported Halloween face paints has repeatedly found heavy metals — lead, cadmium, chromium, nickel — above what any responsible product should carry. FDA's December 2022 final guidance recommends a maximum of 10 ppm lead in externally applied cosmetics.
  • Glitter in a face paint should be cosmetic-grade polyester or plant-derived, never craft glitter, which is cut with sharp edges and is a genuine corneal hazard.

Using it safely

  1. Buy a cosmetic, from a brand that states FDA-compliant colour additives or EU cosmetic compliance, and check the date.
  2. Patch test on the inner arm 24–48 hours before, especially on children.
  3. Not on broken skin, eczema, or an active rash.
  4. Not on the lips or in the eyes unless the specific product is approved for those areas.
  5. Remove it the same day — usually with an oil cleanser or micellar water; leaving heavy paint on overnight is a reliable route to congestion and irritation.
  6. Do not share pots, sponges or brushes between people at an event. Decant, and use disposable applicators.

Where it sits in the rules

Cosmetic in the US — FDA primary category (08), makeup preparations (not eye) — or, for products intended for children, (09) makeup preparations for children (not eye) and (04) children's eye makeup preparations. FDA maintains those as distinct primary categories precisely because children's products warrant separate attention.

Under MoCRA, facilities register and products are listed with FDA, and the small-business exemption does not apply to products that regularly contact the mucous membrane of the eye.

In the EU, the same product is a cosmetic under Regulation (EC) No 1223/2009 with the Annex IV positive list of permitted colorants — 153 entries — governing what may be used at all.

Shelf life

Water-activated cakes are low-water and stable for two years or more unopened; once used with wet brushes and left uncovered they collect skin flora and should be replaced yearly, and always after an event where they were shared. Cream paints follow the usual 12 months after opening. Discard anything that smells off, has changed colour, or was used near an eye infection.