How to start a makeup line, from shade range to first order

Start with the shade range

In makeup, the shade range is the business plan. Every shade is its own batch, its own color match and its own minimum order, so a launch of twelve lipstick shades carries about twelve times the sampling and inventory of one. Starting with one product type and a handful of shades keeps the first order small; add shades once you see which ones sell.

The fastest start is a lab's stock formula in its existing shades, sold under your brand through a private label cosmetics arrangement. Custom shades from the same base usually cost a color-matching fee and a higher minimum. A fully custom formula costs the most, and only makes sense once you know which products sell.

The steps

1. Choose the first product and its shades. Lip, eye and face products carry different color rules, as the next section shows, so decide early where each product will be worn.
2. Choose stock, adapted or custom formulas. Ask each lab for its MOQ per shade and per component, since tubes, compacts and pans often have higher minimums than the fill.
3. Check every color against its use. Get the lab's full color additive list for each shade and check each one is allowed for that area of the body before you approve a sample.
4. Wear-test samples, then approve a standard. Check payoff, wear time and shade under daylight. Keep an approved sample of each shade, because batch-to-batch color matching is judged against it.
5. Collect the color paperwork. For each production batch, ask for the batch certification lot number of every color that needs one, and for heavy metal test results on every lip shade, then on eye and face shades.
6. Label and list the products. Write the ingredient list, including any "may contain" colors, and list the products with FDA. A brand or maker of products that regularly come into contact with the eye's mucous membrane cannot use the small business exemption, as explained below.
7. Inspect and price it landed. A quality inspection checks shade, fill weight, packaging and labels before the goods ship. Then work out the landed cost per unit.

Color additives: the rule that decides what you can sell

US law does not require cosmetic products or ingredients, other than color additives, to have FDA approval before they go on the market^[1]. Colors are the exception: all color additives used in cosmetics must be approved by FDA^[2], and the law bars using a color in a cosmetic unless it is approved specifically for the intended use^[2]. Some colors also need FDA batch certification, lot by lot: such a color may not be used unless the batch in question has passed analysis of its composition and purity in FDA's own labs^[2]. A formula written for another market may name its colors only by Colour Index or E numbers, but FDA says a CI or E number does not indicate FDA certification^[2].

Where the product is worn changes the answer:

• Eyes. A color may not be used in the area of the eye unless the regulation for that additive specifically permits such use^[2]. A pigment approved for blush is not automatically allowed in an eyeshadow or eyeliner.
• Lips. FDA's example: if a color additive is approved for use in externally applied cosmetics, you may not use it in products such as lipsticks unless the regulation specifically permits this use^[2]. Check lip colors separately from face colors.
• Effects. Some colors used in combination may form new pigments that may not be approved for the use. FDA's example is a “holographic” glitter, consisting of aluminum, an approved color additive, bonded to an etched plastic film^[2]. Ask what every shimmer and glitter is made of.

This matters at the border. FDA says color additive violations are a common reason for detaining imported cosmetic products^[2]. Its import alert on color violations counts as uncertified any color additives that require batch certification but do not have a valid certification lot number^[3]. For a cosmetic that appears to contain one, evidence that may help secure release of a detained shipment includes valid FDA certification lot numbers, purchase records, and a corrected label^[3]. Get the lot numbers and the purchase records for each color from the lab with every batch, before the goods ship.

Shades on the label and in the FDA listing

Shade ranges get two practical allowances. On the label, the ingredient list may include an ingredient not in the product if the ingredient is identified by the phrase “may contain”^[4]. That covers a color added to some batches for color matching, and a color in one shared list for a set of shaded products sold under a common brand, with no other brand name on any of them. In FDA's product listing, a single submission may cover multiple cosmetic products with identical formulations, or formulations that differ only with respect to colors, fragrances or flavors, or quantity of contents^[5], so shades that differ only in color need not each be listed on their own.

Registration, the responsible person and safety records work the same way for makeup as for skincare, and the skincare line guide walks through them. The small business exemption is where makeup differs. The law takes it away from any responsible person or facility engaged in making or processing cosmetic products that regularly come into contact with mucus membrane of the eye under conditions of use that are customary or usual^[6], and FDA's own summary says the exemptions do not apply to facilities that manufacture or process, or responsible persons for^[7] products on a list that starts with those eye products. So if your line includes a mascara, an eyeliner or any other product that regularly touches the eye's mucous membrane, plan to list your products with FDA rather than rely on the exemption.

Lead in lip and face products

FDA has draft guidance recommending that lip products and externally applied cosmetics not contain more than 10 ppm lead as an impurity^[1]. It also notes that some cosmetics from other countries contain lead at higher levels^[1]. Exposure to lead from lipstick is mainly by swallowing, such as after a consumer licks her lips^[1], so ask the lab for a lead result on every lip shade, from an outside laboratory, and keep it with the batch records. The recommendation also covers externally applied products such as eyeshadow and blush, so test those shades too.

What a first order costs, landed

Six lipstick shades, 500 units each, from an overseas lab

Line	Amount
Lab price, 3,000 lipsticks at $1.45, filled and labeled, FCA the origin airport	$4,350
Shade matching and development, six shades at $100, one time	$600
Lead and heavy metal tests, six shades at $85	$510
Air freight and insurance	$540
Duty, including any additional duties for the origin, at 2% (assumed) of the lab price and the shade development fee	$99
Customs broker and entry fees	$250
Landed cost	$6,349
Landed cost per lipstick	$2.12

Illustrative figures, not a quote. Real prices depend on the spec, quantity and factory.

The testing and shade development lines are why a wide shade range is expensive to launch: they scale with the number of shades, not the number of units. Launching three shades instead of six would halve those two lines but leave the per-unit lab price where it is. Check the duty line for your origin in the import duty and landed cost guide.

Getting quotes

Tell us the product, the shades and the packaging, and we introduce you to makeup labs that fit, overseas first, each one named; if none fits, we tell you. It is free for brands, and we are not a party to the sale: each lab quotes you directly, and any order is between you and the lab you choose. Ask each lab to state its shipping terms in its quote and to send the color additive list for every shade with any quote you accept, then get the lot numbers with every batch.