One of the things that makes GTX Face Paint unique is the flexibility it gives artists.

Just like a professional hair stylist can purchase a complete salon color system and blend shades to create a custom color for use on a a client, GTX artists can customize their paint palettes to fit their own working style.

Many painters choose to cut larger cakes into smaller sections, combine colors into custom palettes, or organize their kits in a way that best suits their workflow. This is perfectly acceptable when the paint is being used by the original purchaser on their customer, as part of their professional services.

However, there is an important distinction between using a customized palette and selling a customized palette.

Think of It Like Professional Hair Color

When a salon purchases a professional hair color line, the stylist is free to mix shades together to create the perfect color for a client. The stylist then applies that color as part of their service.

What the stylist does not do is repackage that mixture and sell it as a new hair color product to consumers and call it: "Karen's Custom Color Blend"

Why?

Because once a product is altered, repackaged, relabeled, divided, or redistributed for sale, the chain of responsibility changes.

The original manufacturer of any cosmetic (or food, etc.) product designed, tested, labeled, and insured the product as it was originally packaged and sold.

Any subsequent alterations create a new product configuration that was not manufactured, tested, labeled, or distributed by the original manufacturer.

GTX Products Are Intended to Be Used, Not Repackaged for Sale

GTX customers are welcome to:

~Cut cakes into smaller pieces for personal use

~Create custom palettes for their own kit

~Create custom combinations for use on clients

~Rearrange colors to suit their workflow

~Use customized palettes while providing face painting services

~These activities fall within normal professional, GTX-insured use of the product.

However, GTX products may not be divided, repackaged, relabeled, or redistributed for resale.

Examples include:

~Selling individual sections cut from a GTX cake

~Repackaging GTX paint into new containers for sale

~Creating custom palettes for commercial resale

~Removing original labeling and selling portions of the product

~Marketing altered GTX products as a new product offering

~Combining GTX products with other products and reselling the resulting palette

~"Gifting" a palette to a friend. 

GTX maintains product documentation, labeling, ingredient information, batch tracking, safety information, and product liability coverage based on products being distributed in their original form.

When a product is altered and then resold, GTX can no longer verify:

~How the product was handled

~Whether contamination occurred during repackaging

~Whether the original labeling remained intact

~Whether batch information remained attached to the product

~Whether the customer received accurate product information

~Whether the product was stored appropriately before resale

For these reasons, GTX's product responsibility applies only to products sold through authorized channels in their original packaging and condition.

What Happens When You Resell an Altered Cosmetic Product?

When an individual purchases GTX Face Paint and uses it on clients as part of their professional services, they are acting as an end user of the product.

When that same individual alters, repackages, relabels, divides, or combines products and then offers them for sale, they may assume responsibilities that did not previously exist.

Depending on the jurisdiction, those responsibilities may include:

~Product labeling requirements

~Ingredient disclosure requirements

~Batch and lot traceability

~Product recordkeeping obligations

~Product safety documentation

~Product liability exposure

~Regulatory compliance obligations

Anyone considering the resale of altered cosmetic products should consult their own legal counsel, insurance provider, and applicable regulatory authorities before doing so. If you see someone selling product like this, please be VERY CAREFUL about purchasing such products, and think of your own liability. 

GTX does not provide authorization for third parties to manufacture, repackage, relabel, divide, combine, or redistribute GTX products for resale.

GTX does offer a Jam Leader opportunity to artists who want to supervise a GTX Jam- where the end user makes cakes and then proceeds to use them on their own clients. Email hello@gtxfacepaint.com for info on how to become a Jam Leader.

Insurance and Liability Considerations

GTX maintains insurance and product documentation for GTX products as they are manufactured, packaged, labeled, and distributed by GTX.

That coverage and documentation do not automatically extend to products that have been altered, repackaged, relabeled, subdivided, combined, or otherwise modified by third parties.

Artists who choose to create products for resale should ensure they have independently verified:

~Product liability coverage

~Regulatory compliance requirements

~Labeling obligations

~Ingredient disclosure requirements

~Recordkeeping requirements

~Product safety obligations

~CPNP/SCPN/FDA/MOCRA etc. registrations for their products and MSDS sheets. (You should be able to provide this to the customer!)

Failure to do so may expose the seller to risks and liabilities that would not otherwise exist when using the product solely as intended.

Protecting Artists and the Industry

Our goal is not to limit creativity. In fact, we encourage artists to customize their kits and build palettes that work for them. We only exist to support you, the artist!

Customize it, use it and create gorgeous designs!

But if a product is altered and then offered for resale, it is no longer being distributed in the same form in which GTX intended, manufactured, tested, labeled, and sold it. 

The Simple Rule

If you purchase GTX Face Paint and use it on your clients, you're using the product exactly as intended.

If you alter GTX Face Paint and then sell it to someone else, you should assume that the responsibilities associated with that product now belong to you, not GTX.

Artists, if you see "cut cake" sales posts, please report to GTX immediately- hello@gtxfacepaint.com. If you see someone asking for cut cakes, please kindly share this blog post with them. As the brand grows in the industry, our education must also improve so that our artists can flourish and remain safe! 

GTX Face Paint is proud to support professional artists, and we appreciate your help in maintaining the safety, integrity, intention and reputation of the products our entire community relies upon.

Thank you!

Amber