Chlorophyllin allowed in US topical cosmetics? Any other green exempt colorants?

ZinkZink Member
in Color and makeup
Here's a list of colorants that do not need approval from the FDA to use:
https://www.fda.gov/industry/color-additive-inventories/summary-color-additives-use-united-states-foods-drugs-cosmetics-and-medical-devices#table3A

Potassium sodium copper chlorophyllin (chlorophyllin copper-complex): Coloring dentifrices that are cosmetics NTE(7) 0.1% in combination with a list of substances.

Does this mean it can't be used at all in a formula even if not primarily as a colorant? 

https://chemistscorner.com/the-challenges-of-formulating-a-natural-cosmetic-line/ this mentions it is allowed but that seems to be wrong.


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Comments

  • natzam44natzam44 Member
    My understanding is that you would have to be able to prove that you are not using it as a colourant. As you might imagine, this can be quite the hard sell when your product is greener than grass. 
  • ZinkZink Member
    It is an antioxidant but that is perhaps not reason enough? The product is already somewhat green from sencha green tea.
  • natzam44natzam44 Member
    edited February 2021
    Zink said:
    It is an antioxidant but that is perhaps not reason enough? The product is already somewhat green from sencha green tea.
    I know that in Canada and the US, the regulatory agencies are very strict when it comes to colour in products. The problem with using arguments of function is that there are many ingredients with similar functions. A regulator might question why you didn't seek another ingredient which wouldn't change the colour of the product. 

    Keep in mind, that while I have read the laws and regulations, I am not an expert. With that being said, when it comes to possible legal issues, I would recommend erring on the side of caution.
  • PharmaPharma Member, Pharmacist
    You might get away with the marketing for a copper complex product if, say, you also add copper peptide and/or other copper salts... which are usually blue and might turn your product cyan.
    Else, you'll have a very hard time justifying chlorophyll in a product. In some countries, chlorophyll is used to mask off-putting smells such as halitosis. If you could add a stinky molecule as 'active' and mask its reek with chlorophyll...
    (Sorry, I guess I've been watching too much Rick & Morty lately :blush: .)
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