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An Update on MN Statute 325E.3892

From your friends at the Art Cellar January 17, 2025

MN Statute 325E.3892 is a new state law that went into effect in August 2023. This statute puts restrictions on the import and sale of products that contain Cadmium and Lead.

The art materials industry is hoping to obtain an exemption from this statute, but until then, we wanted to provide some helpful information, alternatives, and tips that might alleviate the stress of coping with this new legislation.

Consider Alternatives

Cadmium Red vs. Cadmium Red Hue

When we talk about alternatives for these pigments, it is important to define what “hue” means in the context of paint being sold today. When a color name is followed by the word “hue” (i.e. cadmium red hue), it contains a mix of several different pigments in an approximation of the color named. So, a “cadmium red light hue” will most likely contain several non-toxic pigments that come together to be a good approximation of “cadmium red light pure.”

BUT, paints that do the best at mixing are going to be products with only one, maybe two, pigments.

Hues will often change temperature unpredictably or become grey much faster than pure colors when mixed. This is especially important when learning to mix colors or aiming for a specific color.

If you are not mixing a color, then a hue might be a good product to use, but if you are mixing you might need to get a little more creative.

Synthetics

Newer synthetic pigments can be some of the most effective replacements for cadmiums, though of course they come with their own eccentricities. Often, the pigments we suggest as replacements will be significantly more transparent than their cadmium equivalents. They will also be noticeably warmer or cooler in color temperature. To get around this you would need to apply them on top of lighter colors, mix white into the paint to make it more opaque, or adjust the temperature with other colors.

Here are a few examples:

Cadmium Red Example

In a palette that contains “Cadmium Red Light” and “Cadmium Red Medium” we would suggest replacing “Cadmium Red Light” with “Quinacridone Red” and “Cadmium Red Medium” with “Napthol Red.” In this example, the light and medium cadmium reds are replaced with a cold red and a warm red. While cadmium tends to have a warmer color, it does allow for a variety of color temperatures, and so with these suggested replacements we’re allowing for a variety of color temperatures, if not greater temperature variation.

Cadmium Yellow Example

Similarly, when we replace “Cadmium Yellow Light” and “Cadmium Yellow Medium,” we are going to replace them with a cold and a warm yellow respectively. In this example, we would replace “Cadmium Yellow Light” with “Hansa Yellow Light” and "Cadmium Yellow Medium” with “India Yellow.”

Our Recommended Replacements

For Oil Paint, we carry the full color range of Gamblin 1980 and Gamblin Artist's Oil Color. Because Gamblin does not currently have cadmium hues available in these lines, our suggestions come from what we have available:

Recommended Replacements for Oil Paint

Cadmium Reds Napthol Red, Napthol Scarlet, Perylene Red, Quinacridone Red,

Alizarin Crimson

Cadmium Yellows India Yellow, Hansa Yellow (light, medium, & dark)

Cadmium Orange Permanent Orange

Cadmium Green Permanent Green Light

For Acrylic Paint, we have a select range of Golden Acrylics. While we do carry all the cadmium hues that Golden Acrylics currently offers, they do not yet make hues of all their cadmium colors. We also carry Sennelier Abstract Acrylic, a brand that does not sell genuine cadmium colors. So for acrylics, here are our recommendations:

 Recommended Replacements for Acrylic Paint
Cadmium RedsVermillion (Sennelier), Cadmium Red Hue (light & medium), Primary Red (Sennelier), Pyrrole Red (light & dark), Napthol Red (light & medium)
Cadmium YellowsPrimary Yellow, Cadmium Yellow Lemon Hue, Cadmium Yellow Hue (medium), Hansa Yellow Opaque, Diarylide Yellow, Titanate Yellow, Benzimidazolone Yellow (medium & light), Bismuth Vanadate Yellow
Cadmium OrangeVat Orange, Pyrrole Orange, Cadmium Red Orange Hue
Cadmium GreenPermanent Green Light

The statute not only affects oil and acrylic paint, but any media containing cadmium or lead. As it currently stands, most items do not have easy replacements. If you would like more information or assistance choosing alternatives for non-paint media, feel free to send us an email at mcadartcellar@mcad.edu.

Some Historical Context

When thinking about alternatives for colors containing lead and cadmium, it helps to have a bit of context on why these heavy metals have been used for so long.

Lead paint was first used in the 4th century BCE and was popular for its opacity, density, and brightness. Cadmium is much newer but quickly became popular for many of the same reasons lead was popular: that opacity, density, and brightness of these pigments is hard to compete with. Because these pigments are so good at what they do, they have remained at the core of the artist's palette for over 100 years.

Over time, lead and cadmium popped up in many different products, ranging from children's toys to lipstick. By the 20th century it became clear that these pigments were incredibly toxic and dangerous, yet they are so effective at making things brighter and more opaque that we still encounter them in children’s toys and a variety of foods.

In the past 60 years, titanium has replaced lead as the most popular white pigment. But cadmium remains the most popular red pigment and the most popular yellow pigment for artist materials.

In Conclusion

Thank you for your patience as we navigate news of this statute together. Art Cellar is here to support you, so as always, feel free to send us questions via email at mcadartcellar@mcad.edu.

Posted: 
Tuesday, January 21