In the spray tanning world, creativity is encouraged… but when it comes to product formulation, that’s one area where professionals should never experiment.
Right now, we’re seeing two worrying trends:
- Spray tan professionals altering existing products – the most common example is diluting tanning solution with distilled or demineralised water to make DIY face tan waters, or mixing DHA into moisturisers to create homemade tan extenders.
- Small businesses making their own cosmetics from scratch at home – things like soaps, body scrubs, or body creams, often without proper testing, FDA listing, or compliant labels
On the surface, both practices might seem harmless. After all, you’re just “adjusting” an existing product or “making something natural”. But the reality is much more concerning. In both cases, the end result is an unstable, untested, and non-compliant cosmetic.
THE SCIENCE BEHIND DHA
The active tanning ingredient in solutions is Dihydroxyacetone (DHA), and it’s incredibly unstable. To work effectively and safely, DHA must be supported by:
- The correct pH balance
- Stabilisers to slow down degradation
- Preservatives to prevent bacteria and mould
When you add water, or mix DHA into products that were never designed for it, you disrupt this delicate balance. DHA becomes even more unstable, breaking down faster, and the product’s safety profile changes completely.
THE PRESERVATIVE PROBLEM
Preservatives aren’t “one size fits all.” They’re carefully calculated during the original formulation process to protect the full volume of that product. When you dilute with water, or add DHA to a moisturiser or cream, those ratios change.
That means preservatives are no longer effective, and the product is now vulnerable to bacteria, mould, and contamination. Because the water or base product isn’t sterile once it leaves the lab, the risk grows every time the container is opened.
Your “DIY cosmetic” could become unsafe to use within days… long before you’d ever notice a visible problem.
THE PERFORMANCE PROBLEM
Aside from safety, DIY mixing dramatically affects results.
- DHA breaks down faster, so the tan may not fully develop.
- Patchiness and inconsistent colour are common.
- Fading can become uneven, leaving clients frustrated.
When clients get unpredictable results, they don’t blame the DIY… they blame the professional who supplied it. This puts your reputation and client trust at risk.
THE BIGGER DIY COSMETICS PROBLEM
It’s not only face tan waters being mixed up. Across the beauty industry, people are also:
- Adding DHA into moisturisers to create homemade “tan extenders.”
- Mixing tanning solutions into body creams or whips.
- Attempting to make their own soaps, scrubs, or body products.
Here’s the reality:
- Even if a product doesn’t contain DHA, it is still classified as a cosmetic under MoCRA in the USA (and under similar laws in AU/NZ/EU).
- That means it must be manufactured in a registered facility (if applicable), listed with the FDA (unless exempt), and labelled correctly.
- Without lab stability testing and preservative efficacy testing (PET), there’s no guarantee it’s safe or effective.
And when DHA gets added into the mix, the risks multiply. DHA destabilises formulas not designed for it, preservatives no longer work as intended, and the product becomes unpredictable, unsafe, and 100% non-compliant.
THE COMPLIANCE & LEGAL SIDE
This is where things move beyond “not recommended” into flat-out non-compliant.
With the Modernisation of Cosmetics Regulation Act (MoCRA) now in effect in the USA (FDA Link), cosmetics fall under strict rules:
- Facility Registration & Product Listing: Most facilities and products must be registered/listed with the FDA.
- The $1M Exemption: Some very small businesses with less than $1M in U.S. sales over 3 years are exempt from facility registration, product listing, and GMP requirements.
- But Not All Products Qualify: The exemption does not apply to cosmetics that:
- Contact the mucous membrane of the eye
- Are injected
- Are intended for internal use
- Or – most relevant to us – alter appearance for more than 24 hours under normal use
Spray tan solutions, face mists, and tan extenders clearly fall into this last category. Even though the bronzer washes off in the shower, the DHA reaction with the skin alters appearance for days. That makes tanning products ineligible for the $1M exemption.
Labelling Requirements Still Apply
Even for products that do qualify for the <$1M exemption (like some soaps or bath products), all cosmetics must still have fully compliant labels.
That means:
- Ingredients listed by their proper INCI names, not marketing names.
- Dual net contents in both U.S. customary units and metric (e.g., “1000 mL / 33.8 fl. oz.”).
- Warnings and safe use directions where appropriate.
- A batch/lot code for traceability.
- The business name and contact details for adverse event reporting.
- And in future, disclosure of fragrance allergens once FDA finalises the required list.
In short: even if a brand is exempt from registering its facility or products under MoCRA, it still cannot legally sell cosmetics in the USA without compliant labels.
THE $1 MILLION MYTH
One of the most common misunderstandings about MoCRA is the <$1M exemption.
Some people believe:
“If your business makes less than $1M annually, you don’t have to follow MoCRA and can make your own tanning waters or cosmetics at home”.
Here’s the truth:
- The exemption only applies to some paperwork (facility registration, product listing, GMP) for certain cosmetics.
- It does not apply to tanning products at all, because they alter appearance for more than 24 hours.
- Even exempt businesses must still ensure their products are safe, labelled correctly, have a Responsible Person, and report adverse events.
If the exemption really meant “no compliance,” then even brands under $1M wouldn’t have to list their products with the FDA. But tanning solutions don’t qualify for the exemption, so they must be registered regardless of sales volume.
THE GMP CONFUSION
Another big misunderstanding is about Good Manufacturing Practices (GMP).
Some believe that small businesses under $1M don’t need to follow GMP at all. That’s not true.
MoCRA is finalising mandatory GMP standards (expected to align with ISO 22716). While <$1M businesses may be exempt from registering their facilities, they are still expected to produce cosmetics in safe, sanitary, and controlled conditions.
For example, some wholesalers re-bottle products in “filling stations” at warehouses and claim they don’t need GMP under MoCRA. That’s incorrect. Even if exempt from paperwork, they are still responsible for GMP-level standards, safety, and traceability.
BE CAREFUL WITH “QUICK GOOGLE ANSWERS”
Part of the confusion comes from AI-generated summaries in Google search results. These often oversimplify MoCRA and make it sound like businesses under $1M don’t have to comply at all.
That isn’t the case. While very small businesses may be exempt from some paperwork, all cosmetics must still be safe, labelled correctly, and follow MoCRA’s safety and reporting rules. And tanning products, because of their category, are not exempt at all.
PROFESSIONAL RESPONSIBILITY
As professionals, our responsibility is to protect our clients and uphold industry standards. Altering formulas – no matter how simple it seems – undermines both.
- You risk client safety.
- You risk damaging your business reputation.
- You risk drawing regulatory attention to the entire spray tanning industry.
The safest choice is always to use products that are lab-tested, certified, and approved for cosmetic use.
CONCLUSION
Whether it’s mixing tanning solution with water, adding DHA to a moisturiser, or creating your own soaps and scrubs… the outcome is the same: you’ve made a new, untested cosmetic that is unsafe and non-compliant.
And when it comes to tanning products specifically, the <$1M exemption doesn’t apply. These products are legally required to be manufactured in compliant, FDA-registered facilities, with proper listings and labels.
Leave the formulating to the labs. Protect your clients, your reputation, and the industry by sticking to certified, ready-made formulas.
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