Sunless Tanning Regulations

Amy Thorlin Comments

Sunless Tanning Regulations

by Amy Thorlin

Understanding FDA regulations pertaining to sunless tanning services enable salon operators to provide a higher level of service to customers and serve as responsible representatives of the indoor tanning industry.

Legal Terms Defined

A common question posed to NTTI is whether sunless airbrushing is regulated. This is an understandable question given the fact that roughly 40 percent of U.S. tanning salons offers at least one form of sunless services, and 22 percent offer sunless airbrush or turbine tanning. Many salons have realized the potential growth that sunless services can bring to their businesses.

Responsible tanning salon owners and operators need to be certain they are in compliance with state and federal regulations. They also should make their voices heard when legislative changes are proposed.

State Regulations

Due to the popularity of sunless tanning, some states have enacted or are considering proposing regulations for sunless services. Currently, Oregon and Arizona have deemed that airbrush technicians fall under the scope of their Boards of Cosmetology, which require for licenses for airbrush technicians. It is sensible for salon owners offering sunless application to check with their State Boards of Cosmetology to find out if requirements or pending legislations exist related to sunless services. (Stay current with the latest in state regulations governing tanning by visiting

Federal Regulations

On July 1, 2003, the Food and Drug Administration (FDA) released a statement about dihydroxyacetone (DHA), the main active ingredient in sunless solutions and a color additive for use in adding color to the human body. Section 721 of the Food, Drug, and Cosmetic Act (FD&C Act) authorizes the regulation of color additives, their uses and restrictions. A color additive is considered unsafe under the law if it is not permitted by regulation or it is used in a manner that does not comply with the regulations authorizing its particular use. In addition, no color additive may be used in cosmetics intended for use in the area of the eye unless the color additive is permitted specifically for such use (21 CFR 70.5a).

Practicing Safety

It is important to note that use of DHA in cosmetics is restricted to external application, meaning it only may be applied to external body parts. According to the FDA statement, areas to be protected from exposure to DHA are eyes and the surrounding eye area, lips and other parts of the body covered by mucous membranes. Internal exposure caused by inhaling or ingesting the sunless solution also is restricted.

Operators can take simple steps to ensure consumers adequately are protected from exposure. Spraying only should take place in a well-ventilated area with an overspray booth or fans with filters to remove the overspray. A nose filter or barrier product such as petroleum jelly should be used to protect the mucous membranes such as lips. Disposable undergarments can be used to protect the more private mucous membranes. Clients can avoid getting the solution into their eyes by using eye protection. Disposable eye protection may be a good option. Although sunless solutions contain no known toxins, the repeated inhalation—as with any substance—may cause irritation. Common sense dictates technicians should wear a filtering mask while spraying clients.

To learn more about the sunless process and regulation issues, review the Sunless Airbrush/HVLP Technician course at


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