FAQ : Natural colours

Frequently asked questions about the Rang Dulaar colours

  1. How safe is safe?

The Safe Festival Campaign started from a  concern for the chemicals used in Holi colours that were being sold on the streets  until about a decade ago with no information on the source, the ingredients or knowledge of the impacts of these colours on skin and health. In particular the presence of heavy metals in such chemical dyes or colour powders.

Heavy metals exist in Nature and are increasingly found in our environment and the products we use.

No standards exist in India for the permissible safe limits for such colours used on human skin. Scientists say that there can be no safe limits and even very small quantities can affect our health, advocating that there should be zero lead content in products we create.

However, in an environment that has been polluted beyond measurable limits heavy metals may exist in our soil, in our water and find their way into our lives in many ways.

The safety of the colours have been determined while considering various factors as described below.

2. What category do Holi colours fall under?

Natural Holi colours are a relatively new product and therefore the government does not yet specify under which category they should be considered. Some manufacturers are classifying them as dyes or paints, some are putting them under the category of toys and we consider them to be closer to cosmetics as they are  used on the skin. However they are neither a food product, nor a drug nor a cosmetic for regular use.

  1. What are the safe limits for presence of heavy metals in cosmetics?

The safe limits specified for presence of heavy metals in cosmetics differ from country to country. The Indian Drugs and Cosmetics Rules, 1945 say that the permitted synthetic organic colours and natural organic colours used in the cosmetic shall not contain more than

2 ppm of Arsenic calculated as Arsenic trioxide,

20 ppm of lead calculated as lead,

100 ppm of heavy metals other than lead calculated as the total of respective metals.

(PPM stands for Parts per million which effectively is mg/kg. 1ppm = 1 mg/kg)

In Canada the limits for lead have been lowered to 10ppm . In the European Union each cosmetic is considered individually for the way in which it is used and for the duration it stays on the body and the possible exposure it creates.[1]

Heavy metals impact the body through accumulation and repeated use of cosmetics that are used repeatedly such as eyeliners, kajals and lipsticks.

The Rang Dulaar Holi colours are a one time use product and the expected duration that they may be stay on the skin for varies between 1 to 3 hours.

The Rang Dulaar colours comply with the Drugs and Cosmetics Rules, 1945 although they are strictly for external use and are used one time in  a year.

Ideally, colours should not contain any heavy metal content. However, as this may not always be feasible the European Union has a criteria called ALARA : which stands for As Low as Reasonably Achievable.

It  is important that such permissible limits and standards are established for all cosmetics in India too.

  1. How are the colours made?

The Rang Dulaar colours are made using natural ingredients such as turmeric, beetroot, indigo, and rice flour.

These ingredients are sourced either directly from farmers when possible or through traders that deal with food material. We ask for a food certification from the vendors but may not always get it from farmers.

In a very simple process of mixing these ingredients are put together – each colour has one ingredient that provides the colour and one that acts as a filler.

  1. What is the difference between natural and organic?

A natural material is one that is found in nature and has not been through a process wherein its inherent properties are broken down to separate its active elements.

An organic material is one that is grown in soil that does not have significant levels of chemicals and in the growing of which no chemical pesticides or fertilizers have been added.

The Rang Dulaar colours are natural, not organic.

We believe that organic food is precious and must be used as food or for medicinal purposes rather than for colours.

  1. What lab tests do you conduct?

The Rang Dulaar colours are lab tested in accredited labs in Pune and are tested for  the levels of the following  heavy metals – Lead and Mercury.

We start by testing the raw materials that we source to see the levels of heavy metals in them.

The natural food powders we source may some times contain these in trace elements as they exist in soil and water and there may be pesticide residues in the powders.  We ensure that these are within the permissible limits for drugs and cosmetics before we use them.

If necessary we also test the colours for unwanted organic matter through another test.

We conduct actual informal tests on users through groups of volunteers that are invited to use and keep the colour on their skin for a few hours at a time in wet and dry condition.

Testimonials from  users over the past eight years have convinced us that the colours have not triggered allergies or skin rashes in the majority of people that have used them.

  1. Are the colours made in a factory?

The Rang Dulaar colours offer livelihood options to under privileged women and challenged youth. They are made and packaged in a decentralised manner in homes and at the location where the women live and work. For five years the colours were packaged in the prison offering an income source to the women prisoners of the Yerawada Jail.  In this process of moving handling and storage of the colours we ensure  a basic level of hygiene.

For 2022 the colours have been made and packaged by the women of Ahwalwadi village who have been trained by eCoexist.

  1. How are the colours packaged?

Womens groups package the colour in brown paper pouches which are then put into a cardboard box. We only use plastic for larger quantities.

The package mentions the ingredients used in the colours clearly  as well as the groups that are making them.

Paper boxes that have not been used in any particular year are then covered with beautiful cloth and converted into gift boxes by a group of mentally challenged youth in Pune called Dilasa, recycling them into another product that helps them to earn.

  1. How are the colours stored?

The colours do not have a strict expiry date but are best used within four to six months of manufacture. Following this duration they become vulnerable to attack by rice weevils. If stored under cold storage conditions they could be kept for the following year as well.

Colours that are stored in cold storage can be checked for organic matter before being used. Through a simple process of sieving and heating they can be made as good as new.

  1. Do the colours stain the skin and your clothes?

When used along with water, ingredients such as turmeric and beetroot do leave a stain on the skin, which normally can be washed off within a day.  In the dry form , the colours come off very easily.

Stain on clothes also come off very easily in a few washes.

  1. What happens if the colours are accidentally ingested?

The Rang Dulaar colours are meant for external use only. They have not been tested for ingestion. Sometimes in the process of play, powder may enter your eyes or ears and nose and if washed off immediately these should not have a detrimental effect.

Normal levels of irritation that occur when any powders enter the eyes are  possible, however washing with water provides relief.

If you are aware of a skin or eye condition, please be careful in your use of any Holi colours.

We recommend that eye lenses are not worn while playing Holi , you can wear glasses that help you see as well as protect your eyes.

  1. Will the colours stain flooring or damage lawns?

The Rang Dulaar colours are made of natural materials, When used on the soil or on a lawn they are expected to be absorbed by the earth in a few days. If large quantities of the colours enter water drainage systems they may cause clogging of pipes as there is some sediment when the colours are mixed with water.

  1. Why are the colours expensive?

The current cost of production of the colours is about one third of the retail price of the Rang Dulaar colours. For 2018, the MRP for the colours is Rs 800 per kg. A 20 – 25% commission is offered generally to distributors and stores and costs of logistics and storage also add upto around Rs 150 per kg. Rates for labour are discussed with womens groups to arrive at a fair price and all the logistics to bring the colours to their locations are covered by us. No investment is expected on behalf of the womens groups and advances are given to assist them to organise themselves to be able to take on the job.

The decentralised model through which eCoexist works demands a lot more effort and time as compared to a factory production and this leads to the higher cost of the colours.

To offset this, eCoexist offers ideas through which people can make their own colours and also arranges events for underprivileged children that may not be able to afford the colours.

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This document is to share the processes and considerations that the Rang Dulaar colours are subject to.

Lab test reports are available on demand via hard copy sent through post.

The Rang Dulaar colours have been tested at NAFARI and MAARC Labs in Pune.

For any queries or clarifications please contact us at [email protected]

[1] The European Cosmetics Directive (76/768) and the new Cosmetics Products Regulation (1223/2009) allow the non intended presence of small quantities of a prohibited substance, stemming from impurities of natural or synthetic ingredients, the manufacturing process, storage, migration from packaging, which is technically unavoidable in good manufacturing practice, provided that such presence does not cause damage to human health when the product containing the trace is applied under normal or reasonably foreseeable conditions of use.

Ref: REPORT FOR INTERNATIONAL COOPERATION ON COSMETIC REGULATION (ICCR)

Principles for the handling of traces of impurities and/or contaminants in cosmetic products