Is ophthalmological testing mandatory for liquid eyeliner?

Under European Regulation (EC) No 1223/2009, animal testing is completely prohibited. Safety must be demonstrated through validated non-animal methods. The Safety Assessor relies on in vitro ocular irritation assays (HET-CAM or BCOP) and clinical trials conducted under ophthalmological supervision ("tested under ophthalmological control") to confirm that the product causes neither stinging, lacrimation, nor corneal micro-lesions.

Can I market a waterproof eyeliner formulated without silicones?

Yes. Waterproof and water-resistant claims can be achieved by utilizing natural vegetable waxes (carnauba, candelilla), plant-derived pullulan, or natural resins (shellac, rosin derivatives) combined with volatile natural esters. To support the "waterproof" claim on packaging, standardized laboratory water-immersion wash-off tests must be conducted and documented in Section 4 of the PIF.

What is the maximum allowable PAO for an eyeliner?

Due to repeated periocular application and direct exposure of the applicator to eye microflora, the Period After Opening (PAO) for liquid eyeliners rarely exceeds 6 months (indicated by the open jar symbol: 6M). A longer PAO must be substantiated by rigorous preservation challenge testing and user in-use microbial challenge assays.

Eyeliner & Eye Makeup: PIF & Regulation

Eyeliner: Formulation, Ocular Safety, and European Regulatory Compliance

Eyeliner is a defining cosmetic in eye makeup, whether packaged as a liquid formula with an ultra-fine brush applicator, a precision felt-tip pen, or a creamy compact gel. Its application directly along the margin of the eyelid, in close contact with Meibomian glands and adjacent to the corneal epithelium, makes it one of the most sensitive cosmetics to formulate and evaluate for toxicological safety. In Europe, commercialization demands strict compliance with Regulation (EC) No 1223/2009. From black colorant purity verification to ocular toxicological safety assessment, discover our complete regulatory guide.

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Formulation Constraints for Eyeliner: Pigments and Film-Forming Agents

Formulating a high-performance eyeliner requires combining intense pigmentation, smudge-proof long-wear resistance, and absolute ocular harmlessness:

Selection of colorants (iron oxides and carbon black): black iron oxide (INCI: CI 77499) and carbon black (INCI: CI 77266 [nano]) are the primary reference pigments. The use of carbon black in its nano-structured form is strictly governed by Annex IV of the Cosmetic Regulation, requiring high chemical purity (> 97% pure carbon) and a specific notification on the CPNP six months prior to placing on the market if non-standard specifications are used.
Film-forming agents: synthetic acrylate polymers or natural waxes that deposit a continuous water-resistant barrier upon drying, preventing flaking and smudging throughout the day.
Solvent phase: predominantly ultra-pure demineralized water for standard liquid eyeliners, demanding robust microbiological preservation.

The PIF compiles all technical formulation specifications, colorant purity assays, and stability assessments. To understand the overarching European regulatory requirements for color cosmetics, consult our guide on makeup cosmetic regulation and our reference page on the general cosmetic PIF.

🔬 Insights from our Cosmetic Safety Assessor

"Due to immediate application in close proximity to the cornea and palpebral mucous membranes, in vitro ocular tolerance testing (HET-CAM and BCOP) is an essential component of the eyeliner regulatory file. Furthermore, microbiological purity must be pristine: as a Category 1 cosmetic under ISO 17516, total aerobic mesophilic microorganism counts must remain strictly below 100 CFU/g with a confirmed absence of Pseudomonas aeruginosa, Staphylococcus aureus, and Candida albicans. Performing an ISO 11930 challenge test is a non-negotiable prerequisite to validate formula safety."

Steps for Regulatory Compliance of Your Eyeliner Line

To market your eyeliner legally in France, Switzerland, and across the EU, you must complete the following stages:

Stability and container-content compatibility testing: accelerated stability testing at 40°C for 8 to 12 weeks to confirm that the liquid formula does not coagulate, that pigments do not cake, and that applicator brush bristles or felt tips do not dry out or shed fibers.
Microbiological challenge testing (ISO 11930): demonstrating that the preservative system remains effective against repeated consumer contamination during daily use.
Cosmetic Product Safety Report (CPSR): drafting and sign-off of Parts A and B by our qualified Safety Assessor. Ocular tolerance assays, raw material purity certificates, and exposure calculations are thoroughly audited.
Labeling compliance review: verifying the mandatory INCI list, net volume, batch number, PAO (Period After Opening) symbol, and periocular safety instructions.
CPNP notification: mandatory product registration on the European Cosmetic Product Notification Portal prior to distribution.

Our regulatory team provides turnkey support for your cosmetic projects. Review our service packages and pricing in our dedicated PIF services guide.

⚠️ 3 Frequent Regulatory Risks in Eyeliners

Using unapproved or uncertified colorants: applying pigments not explicitly authorized in Annex IV for eye-area use leads to immediate market recall.
Microbiological contamination from applicators: liquid eyeliner brushes dip repeatedly between the skin and the container reservoir. Without a verified preservative system, microbial proliferation poses severe risks of bacterial conjunctivitis or keratitis.
Applicator fiber shedding or leaking: poor packaging quality control resulting in leaking barrels or shedding felt tips breaches safety and physical quality standards under Good Manufacturing Practices (ISO 22716).

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Cross-Regulatory Links with Related Eye Cosmetics

If you are expanding your eye makeup collection, review our related technical guides:

For pressed and loose powder shadows, see our guide on eyeshadow pigment regulation.
For lash formulas and mascara wands, consult our guide on mascara eye safety PIF.
For overall ocular makeup regulatory criteria, read our guide on eye makeup regulation.

Frequently Asked Questions About Eyeliner PIF

Is ophthalmological testing mandatory for liquid eyeliner?: Under European Regulation (EC) No 1223/2009, animal testing is completely prohibited. Safety must be demonstrated through validated non-animal methods. The Safety Assessor relies on in vitro ocular irritation assays (HET-CAM or BCOP) and clinical trials conducted under ophthalmological supervision ("tested under ophthalmological control") to confirm that the product causes neither stinging, lacrimation, nor corneal micro-lesions.
Can I market a waterproof eyeliner formulated without silicones?: Yes. Waterproof and water-resistant claims can be achieved by utilizing natural vegetable waxes (carnauba, candelilla), plant-derived pullulan, or natural resins (shellac, rosin derivatives) combined with volatile natural esters. To support the "waterproof" claim on packaging, standardized laboratory water-immersion wash-off tests must be conducted and documented in Section 4 of the PIF.
What is the maximum allowable PAO for an eyeliner?: Due to repeated periocular application and direct exposure of the applicator to eye microflora, the Period After Opening (PAO) for liquid eyeliners rarely exceeds 6 months (indicated by the open jar symbol: 6M). A longer PAO must be substantiated by rigorous preservation challenge testing and user in-use microbial challenge assays.