Nail Polish Supply Chain and Regulations

Goals

Help a startup creating a new form of nail polish application establish their supply chain by understanding sourcing options and regulations for nail polish and remover.

Specifically, the research should identify possible suppliers (domestic or offshore) to supply their chemicals for direct-to-consumer distribution in the US- mainly the leading private label polish manufacturers in the US and overseas, as well as the leading cosmetic and CPG warehouses in the US for distribution. It should also drive understanding of all of the restrictions involved in buying, storing, and selling nail polish and acetone based removers.


Early Findings

Restrictions on Nail Polish

  • In general, the nail products industry (including polish and remover) is not highly regulated at the federal level. However both the U.S. Food and Drug Administration (FDA) and the Occupational Safety and Health Administration (OSHA) have specific regulations.
  • The FDA is primarily concerned about making sure that labeling properly warns customers of the risks. Title 21 of the Code of Federal Regulations states that warnings must document all risks, be in bold type and placed somewhere conspicuous and in a different color from the rest of the label.
  • The label also has to list all ingredients, in descending order of predominance.
  • Each dye used in the nail polish must be tested by the FDA, approved and certified safe from health risks.
  • Chemical composition is also regulated. Up to 50% of the nail polish can be made from tuolene, 10% can be made from phthalates, and formaldehyde is allowed but only up to 0.2% of product weight.
  • OSHA rules state that manufacturers have to provide material data safety sheets to employees and salons. Employees involved in manufacturing have to be trained, and miust have protective equipment when handling any toxic chemicals. Air quality testing should be done- at maximum, there should only be 200 parts per million of tuolene over an eight-hour period.
  • There should be a safety data sheet (SDS) for each product that has a "hazardous chemical at 1% or more (or at 0.1% or more for chemicals that may cause cancer) or that could be released into the air above limits set by OSHA or the American Conference of Governmental Industrial Hygienists (ACGIH)". Each sheet is meant to educate workers on the health risks and possible precautions. These include what the ingredients are, how the workers might be exposed, health and safety risks when using it, and precautions for using and storing it (including what to do in emergencies).
  • IF respiratory equipment is required, then there has to be a program for protecting respiratory health that adheres to OSHA's guidelines spelled out in OSHA's Respiratory Protection Standard, 29 CFR 1910.134.
  • Of course, there may be state regulations that will differ wildly but tend to be stricter than federal guidelines.


Restrictions on Acetone

  • The restrictions on acetone are a subset of the regulations listed above (for the safety data sheet). A sample may be found here.


Suppliers

  • A list of private-label nail polish manufacturers in the US can be found here. A global list can be found here.
  • While most warehousing may promise to be able to handle nail products, there are several considerations that should be taken into consideration. For example, industry knowledge and experience with special regulations governing cosmetic storage will be helpful, as will more general advantages like location, e-commerce capabilities, security, and flexible space. One example is ODW Logistics, which lists Cosmetics as one of their expert industries, USAFill, which provides quantitative data to back up their claims of quality, and Symbia Logistics, which has a long list of credentials and certifications as well as locations across the US.


  • In sum, the initial findings have already been able to pinpoint the possible private label polish manufacturers (both domestic and offshore), as well as possible warehouses in the US for distribution. An overview of the restrictions on nail polish has also been provided. These findings have informed the recommendations below.

Proposed next steps:

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