Can you colour lip balm with crayons, lipstick or eyeshadow?

Crayons no, even AP non-toxic ones; a finished lipstick yes, at about one part to three of balm; eyeshadow no, because many eye colours are not listed for lips.

Crayons, no. A finished lipstick, yes. Eyeshadow, no. Crayola itself says it does not recommend using its crayons to make lipstick and "strongly discourage[s]" it, and the "AP non-toxic" seal on the box is an art materials certification for use as intended, which is drawing, not a cosmetic approval for lips. A lipstick is already a lip product, so every colour in it was chosen to be legal and safe on lips, and diluting it in a clear balm can only lower each colour's concentration. An eyeshadow is made for the eye area, and in the United States the eye area and the lips are covered by different lists: ultramarine blues, Prussian blue, chromium greens, aluminium powder and the bone char black D&C Black No. 3 are all permitted around the eyes and none of them is permitted on lips.

• Crayons: no, maker says so
• AP seal: art use, not lips
• Lipstick: 1 part to 3 parts balm
• Red 33 and 36: 3% cap on lips
• Eyeshadow: no, unless labelled for lips

Crayons: no, and what "non-toxic" actually certifies

The usual advice, repeated across craft project pages and forum threads, is to melt a crayon into a balm base and pick a non-toxic brand. It misreads what the non-toxic label is for, and the crayon maker has answered the question directly.

Crayola's own answer to "Is it safe to use Crayola art materials to make lipstick, eyeliner, and other makeup?" is that although its arts and crafts products are nontoxic, "we do not recommend using them to make eyeliner, lipstick, or other makeup, and strongly discourage using them this way." It adds that makeup "goes through specific and rigorous testing" because it is meant for skin, that its "colored pencils, crayons, markers, paint, and all art products have not been tested in the same way a makeup product is", and that they are "not designed, tested, or approved for this purpose." There is no reading of that answer in which a crayon lip balm is a sanctioned use.

The non-toxic wording on the box comes from the Art and Creative Materials Institute. Its AP (Approved Product) seal means, in ACMI's words, that a product is "non-injurious to humans when used as intended" and contains "no materials in sufficient quantities to be toxic or injurious to humans, including children." A board certified toxicologist does the evaluation, and the programme considers skin contact, ingestion and inhalation exposures. That is why a chewed crayon is not a poisoning case, but it is an evaluation of an art material used as an art material. ACMI's own safety page says certified art products are designed for "incidental or limited skin contact as a foreseeable use", and that products deliberately applied to skin, such as face paints, are cosmetics "regulated under the requirements of the Food and Drug Administration (FDA)" rather than by its seal.

So the seal answers "what happens if a child eats a bit of this by accident?" The lip balm question is different: "may this colour go on the lips several times a day, with a share of it swallowed each time?" In the United States that has a legal answer, a list of colours allowed on lips, and the seal is not part of it. A crayon wrapper names no colour additive and no certification lot, so nothing on the box can be checked against that list. The confusion persists because "non-toxic" sounds stronger than it is, and because a crayon is a wax stick of colour that looks like a natural fit.

How the lip rule works in the United States

US colour law does not ask whether a colour is toxic in the abstract. It asks whether the colour is listed for a particular use, and anything not listed for that use may not be used for it. The listings sit in Title 21 of the Code of Federal Regulations: Part 73 for colours exempt from batch certification, such as iron oxides, mica and ultramarines, and Part 74 for synthetic colours that the FDA must certify batch by batch, the D&C and FD&C colours. FDA's summary page states that colours in Parts 74 and 82 "must be analyzed and batch certified by FDA before they can be used in any FDA-regulated product marketed in the U.S."

Each listing gives one of a small number of scopes, and the scope decides whether a colour can go on lips.

• Cosmetics generally. Allowed in cosmetics in general, which includes lips. Some of these also say "including the area of the eye"; those without that phrase may not be used around the eyes.
• Externally applied cosmetics. 21 CFR 70.3(v) defines these as cosmetics "applied only to external parts of the body and not to the lips or any body surface covered by mucous membrane." This is the phrase that rules a colour off the lips. Several of these colours also say "including the area of the eye", which is how a colour can be fine for an eyeshadow and forbidden in a lip balm.
• A named list of products. D&C Black No. 2 may be used in eyeliner, brow products, eye shadow, mascara, lipstick, blushers, foundation and nail enamel. D&C Black No. 3 may be used only in eyeliner, eye shadow, mascara and face powder.
• Lip use with a cap. Three colours are allowed on lips only up to a fixed share of the finished product: D&C Red No. 33 and D&C Red No. 36 at no more than 3 percent total colour by weight, and D&C Orange No. 5 at no more than 5.0 percent. All three are otherwise listed for externally applied cosmetics.

The area of the eye has its own definition in 21 CFR 70.3(s): everything inside the ridges of the brow and the cheekbone, including the eyebrow, the lids, the lashes and the eyeball. FDA's summary adds that a colour permitted for general use "may not be used in the area of the eye" unless its listing says so. The eye and the lips are therefore two separate permissions, granted colour by colour. Neither implies the other, and that is the whole reason eyeshadow fails this test while lipstick passes it.

The colours, sorted by where they may go

The table brings together the colours that decide this question: the ones a lipstick is likely to use, and the eyeshadow staples that cannot go on lips. The US columns come from 21 CFR 73 subpart C and 74 subpart C on eCFR; the EU column, from Annex IV as published on legislation.gov.uk, is explained further down.

Two patterns stand out. Every colour in the bottom half of the US column is a staple of eye products: blues, greens, violets built on ultramarine, metallic silvers and deep blacks. And none of them is cleared for lips at any level, whatever its status around the eye. Fifteen of the certified colours in Part 74 subpart C, from D&C Blue No. 4 to D&C Yellow No. 11, are listed for externally applied cosmetics only, so none of them may go on lips at any level.

A finished lipstick: yes, and how much to use

A lipstick or a solid lip tint is the one borrowed colour source that answers the regulatory question for you. It was formulated to go on lips, so in the US every colour in it has to be listed for lip use, and a capped colour such as D&C Red No. 33 has to sit at or under 3 percent of the stick. Melting it into a clear balm cannot add a colour that was not there or raise one that was. It can only dilute. At one part lipstick to three parts balm, a red capped at 3 percent in the stick is at most 0.75 percent in your tube, and Orange No. 5 capped at 5 percent is at most 1.25 percent.

The figure to start from is 1 part lipstick to 3 parts balm by weight, so 25 percent lipstick. How much colour that carries depends on how much pigment the lipstick holds, which no label states. This site works to 5 to 10 percent total pigment for an opaque lipstick, including titanium dioxide and fillers, in its guide to colourants and tints, and the arithmetic follows from that.

For comparison, the site's own tinted lip balm formula runs 3 to 8 percent total pigment, so a half and half mix reaches the bottom of that band and a quarter mix stays below it. Past about half lipstick you are no longer making a tinted balm. You are softening a lipstick, and a proper lipstick formula with its own wax level and its own mould does that job better.

1. Choose the right lipstick. A bullet lipstick or a solid tint stick, the kind that is wax and oil throughout. If the ingredient list begins with water (Aqua), it will not stay mixed in an anhydrous balm. Liquid and long-wear formulas that are designed to dry down to a film do not blend predictably either. How to read the list is covered in reading a balm label.
2. Weigh, do not guess. Slice the lipstick with a clean blade and weigh it. For one tube, about 1 g of lipstick and 3.2 g of balm base. A kitchen scale that reads to 1 g cannot weigh this; you need one reading to 0.1 g at least.
3. Melt gently. Melt the balm base first in a water bath, then add the lipstick and stir until no streaks remain. A water bath keeps the mix well under 100 C and cannot scorch it, as set out in melting methods.
4. Swatch before you pour. Dip a cold spoon, let the drop set and try it on the back of your hand. Molten balm always looks darker than the set balm. Add more lipstick at this stage, not after the tube has set.
5. Pour and let it set. Pour into a clean tube or tin while the mix is fully liquid. Tube filling technique, including topping up the dip that forms as it cools, is in filling lip balm tubes.

Use a plain, colourless lip balm as the base, or make one from the basic lip balm method, and stir right up to the pour so the colour does not sink to the bottom. Avoid a base with menthol, camphor or a strong flavour if you are making it for a child; the reasons are in lip balm for children. And use a lipstick you have used before without reaction, since diluting it does not change what is in it.

Eyeshadow: no, and the colours that make it a no

Eyeshadow looks like the more natural choice: it is pure pigment in more shades than any lipstick range. It fails because the colours that give it that range are disproportionately the ones permitted around the eye and not on the lips.

Take the shades one family at a time. A blue, navy, purple or lilac eyeshadow very often owes its colour to ultramarines or ferric ferrocyanide, both listed in the US for externally applied cosmetics, including the eye area, and therefore not for lips. A green or teal often uses chromium oxide greens or chromium hydroxide green, in the same position. A bright metallic silver may use aluminium powder, again external and eye area only. A deep matte black may use D&C Black No. 3, a washed bone char made from calcined cattle bones, which is listed for eyeliner, eye shadow, mascara and face powder and for nothing else; it is also the reason a black eye product may not be vegan, a point taken up in vegan and cruelty free labels. The shades most likely to be built only from lip-cleared colours are the earth tones and plain shimmers, made from iron oxides, titanium dioxide and mica.

You might think the answer is to read the ingredient list and pick a pan built only from lip-permitted colours. In practice you cannot. A palette sold in several shades is allowed to list every colour used across the range together, after "may contain" or "+/-", so the list tells you what is somewhere in the palette, not what is in the pan you are holding. That shade-range shortcut is explained in INCI names explained. A single shade sold on its own does list its own colours, but an eyeshadow is also more than its colours: it is a powder made with binders and fillers chosen for the eyelid, and nobody chose them with swallowing in mind.

There is one exception, and the label settles it. A product sold for "eyes, cheeks and lips", or for lips among other uses, is intended for lips, so in the US every colour in it has to be one listed for lip use. If the label names lips, it is a lip product and can be used like the lipstick above. If it does not, treat it as an eye product.

Readers in the EU and UK: what Annex IV changes

The EU and UK use a different list and a different structure, and the answer for eyeshadow is less clear-cut there. Annex IV of Regulation (EC) No 1223/2009 lists the colourants allowed in cosmetic products. Each row gives the substance, its Colour Index number and colour, then a column headed "product type, body parts", a maximum concentration and other conditions. Where the body parts column is empty, the colourant may be used in any cosmetic, lips included. Where it is filled in, it restricts. In the text on legislation.gov.uk, by our count 36 rows are for rinse-off products only, 19 say "not to be used in products applied on mucous membranes", which takes in the lips, four say "not to be used in eye products", and one carries a lip-specific limit: CI 45396 at 1 percent when used in lip products. The preamble adds that a listed colourant includes its salts and lakes.

Read the eyeshadow colours against that text and the EU picture differs from the US one. Lazurite (ultramarine, CI 77007), chromium(III) oxide (CI 77288) and hydroxide (CI 77289), ferric ammonium ferrocyanide (CI 77510) and aluminium (CI 77000) all have an empty body parts column, with purity conditions only. So the colours that make a US eyeshadow off-limits for lips are not off-limits under this EU text. The caps differ as well: CI 12085, the colour sold in the US as D&C Red No. 36, is held to 3 percent in every EU product rather than only in lip products, while CI 17200, D&C Red No. 33, has no EU maximum at all.

Two limits on that. First, legislation.gov.uk carries the EU text as it stood on 31 December 2020, kept up to date as UK law since; we could not retrieve the current EU version from EUR-Lex to check whether these rows have changed. Second, a permitted colour list is not the whole answer. An eyeshadow on sale in the EU or UK has a safety assessment written for its intended use on the eyes, as described in safety assessment and the CPSR, and a lip product is partly swallowed. So in Europe the colours in a single-shade eyeshadow may well be lip-legal, checkable CI number by CI number, but the product is still not a lip product, and a lipstick remains the better borrowed colour.

Where this answer stops applying

Everything above is about making a lip balm for yourself. At home the colour lists are best read as the most careful public judgement of which colours belong on lips, not as a rule anyone will enforce. That is also why the crayon answer does not soften: the reason not to put a crayon on your lips is not that it is illegal at home, it is that neither the maker nor the certifier stands behind that use.

Selling changes the answer, including for the lipstick method. A balm offered for sale is your product, and you have to declare what is in it and show that every colour is permitted for lips in your market. A remelted branded lipstick comes with no colour documentation you can use, and its ingredient list may be a "may contain" block. In the US that labelling duty is covered in labelling cosmetics in the US, and in Europe in selling balms in the UK and EU. A seller should buy documented, lip-approved pigment and work from the iron oxides and mineral pigments guide instead.

Two smaller limits. The lipstick method does not make a lipstick hypoallergenic: carmine, flavour or fragrance in the stick are in the balm too, so a new combination is worth a patch test. And an old lipstick from the bottom of a handbag brings its own contamination and rancidity into a fresh base, so start from a stick in good condition and work with clean tools.

Colour without borrowing it

If you want a tinted balm you can repeat to the same shade, or sell, buy the pigment rather than borrow it. Iron oxides give every shade from a warm nude to a brick red, are permitted on lips in both the US and the EU text above, and do not fade. They need grinding into an oil first, the job castor oil does well, and the full method is in the tinted lip balm formula linked above. Bright pinks, corals and clean reds need certified lakes such as D&C Red No. 7, which is where a borrowed lipstick is, honestly, the easier route for a home maker.

So: crayons and craft colours away; a bullet lipstick at one part to three for a one-off tint; eyeshadow only if its label says lips; bought lip-approved pigment for anything you will make twice.

Reviewed and updated 30 October 2026. Spotted an error? Tell us and we will fix and log it.