Dear Valerie: I read that the EU’s SCCS finalized their opinion and will no longer support the safe use of the dyes Basic Blue 99 and Basic Brown 16. Is this really going to impact hair color or is this just simple reformulation behind the scenes? —Color Me Concerned

Dear Color, 

In short, this is not just a simple reformulation behind the scenes. These final opinions were a long time coming, so having some context to how we got here will be important. And, if you know me, you know I love a good preamble before getting to the answer!

Hair color is one of the few fields within cosmetic science that’s still largely learned person-to-person. I was fortunate to train under a dye synthesis chemist who developed many of the molecules still used today. I credit this experience with my perspective in dye chemistry!

The safety debate of Basic Blue 99 and Basic Brown 16 has been going on for a little more than 15 years and it’s a little messy (to say colorful would have been a little too punny). There isn’t a lack of safety of the dye structures themselves, but rather a lack of toxicology on uncharacterized impurities from the manufacturing processes. Dye synthesis routes are complex, leading to impure mixtures composed of various structures. The impurity profiles vary depending on the dye.

Basic Blue 99 not only has a large impurity profile, but impurity variation from batch to batch. The SCCS has reviewed all data historically and surmised that consumer safety cannot be finalized. The impurity profile for Basic Brown 16 is much smaller but also has historical variation. For this reason, like Basic Blue 99, safety cannot be substantiated. This doesn’t mean they’re unsafe, it just means without more information we can’t say with certainty that they are.

An SCCS opinion doesn’t translate to a direct regulation or ban, but the opinion does get taken into consideration by the European Commission. When regulation is made, Annexes II and/or III would be updated with the respective banning or use restrictions for these dyes. Once regulation is drafted and in place, brands selling in the EU will likely need to reformulate. Even if not formulating for the EU, there is a possibility these dyes may face restriction at the state level in the US and one should take heed. States like CA and WA have already banned particular colorants that aren’t widely used anymore.

This opinion can be impactful because Basic Blue 99 and Basic Brown 16 are ubiquitous in semi-permanent hair color, particularly natural-looking tones. Both are quite unique colors and there is no 1:1 replacement for them. There would be noticeable differences in the hair color result and neat product by switching out either of these dyes. Dyes not only look different in bulk tone (once dissolved in water), but they interact with the hair differently. Since the consumer’s experience will definitely change, a messaging strategy will be quite important.

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Valerie George

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Valerie George is a cosmetic chemist, science communicator, educator, leader, and avid proponent of transparency in the beauty industry. She works on the latest research in hair color and hair care at her company, Simply Formulas, and is the co-host of The Beauty Brains podcast. You can find her on Instagram at @cosmetic_chemist or showcasing her favorite ingredients to small brands and home formulators at simply-ingredients.com