Henna and Mehndi Powder Inspection

Henna and mehndi powder inspection

A henna powder inspection checks pack weight, seals and moisture protection, colour, fineness and grit against the approved sample, and labels for each market, especially hair-only versus skin claims. Lawsone, sand and ash, metals and PPD adulteration are lab results, so the inspector draws and seals samples from the packed lot for an accredited lab.

Last reviewed 14 Oct 2026

Product

Dried, powdered leaf of Lawsonia inermis, sold in bulk bags, retail packs, hair-colour blends and cones

Where it's made in India

Sojat, Pali district, Rajasthan (Sojat Mehndi GI, application 628), about 100 km from Jodhpur

Key rules

US 21 CFR 73.2190 (henna for hair only) and FDA Import Alert 53-19; EU Cosmetics Regulation 1223/2009, with PPD limited to oxidative hair dyes

Typical AQL

General II for pack checks; samples for the lab drawn separately at random

How henna powder is made in Sojat

"Sojat Mehndi" is a registered Geographical Indication: application 628, filed by the Mehndi Vyapar Sangh Samiti of Sojat City, Pali district, with a certificate dated 14 September 2021, valid to 12 November 2028. Sojat is about 100 km from Jodhpur, where Clear To Load is based.

Henna leaves are harvested from field shrubs, dried, then ground and sieved in powder mills. The same leaf goes into very different products. Finely sieved powder is sold for body art; coarser grades go into hair colour. Exporters also sell blends with indigo, cassia or herbs, ready-to-use cones of henna paste, and private-label retail packs. Each step adds a risk: leaf from a different source, stems and sand milled in, moisture picked up in storage, and, at the worst end, a synthetic dye added to darken the stain.

What we check on henna powder

Check	How it is checked	What fails
Net weight	Packs weighed on a calibrated scale, net of packaging, against the declared weight	Packs short of the declared weight beyond tolerance
Seals and barrier	Heat seals pulled and squeezed; liner and zip checked	Open or weak seals, pinholes, missing inner liner
Colour and odour	Compared with the approved retained sample in daylight	Brown, dull or grey powder; musty or chemical smell
Fineness and grit	Rubbed between fingers; hand-sieved through your mesh if you supply one	Gritty feel, stem fibres, residue on the sieve above your limit
Foreign matter and lumps	Powder spread on a white tray	Insects, hair, stones, caked lumps from damp
Labels	Read against approved artwork for each market	Skin or body-art claims on packs for the US market; missing hair-dye warnings, batch code or origin
Cones	Seal at the tip and back; leaks when pressed; paste colour	Leaking or dried cones, no ingredient list
Batch coding	Code and date on pack, inner box and carton against the certificate of analysis	Missing or mismatched codes

Common henna and mehndi powder defects and how they are classed

Defect	Typical cause	Class
PPD or another synthetic dye found by the lab	"Black henna" or "natural black" blends darkened with hair dye	Critical
Skin-use claim on henna for the US market	Generic artwork used for every market	Critical
Lab result over the agreed lead, arsenic or ash limit	Sand and soil milled with the leaf	Major
Open or weak pack seals	Sealer temperature, dust in the seal	Major
Short weight	Filling by volume, poor scale control	Major
Caked or musty powder	Moisture during storage	Major
Colour slightly off the sample	Leaf batch and age	Minor
Smudged print on the pack	Ink not dry before stacking	Minor

Your defect list decides the final class.

Adulteration and the lab tests that matter

The worst risk in henna is not visible. Para-phenylenediamine (PPD), a hair-dye chemical, is added to make "black henna" stain dark and fast, and on skin it can cause severe allergic reactions. Sand, soil and stems are cheaper problems but lower the dye content. The inspector draws samples at random from packed cartons, seals them with numbered tape and sends them to an accredited lab, usually for:

PPD and other synthetic dyes, on every lot sold for skin and on any "black" or "natural black" product.
Lawsone content, the dye in henna leaf, as a measure of quality.
Moisture, total ash and acid-insoluble ash, which show damp storage and sand.
Lead and arsenic, where the US specification or your own limit applies.
Microbiology, if your safety assessor asks for it.

For the US, 21 CFR 73.2190 sets the henna specification: no more than 10% moisture, 15% total ash, 5% acid-insoluble ash, 20 ppm lead and 3 ppm arsenic, and no admixture with other plant species. A blend with indigo or cassia is therefore not plain "henna" under that rule. Tests are arranged through lab testing coordination.

Market rules for henna

US. Henna is a colour additive approved for colouring hair only, not for eyelashes, eyebrows or near the eye (21 CFR 73.2190). Labels must say "Do not use in the area of the eye" and "Do not use on cut or abraded scalp", or equivalent. FDA's fact sheet says henna is not approved for direct skin application, and Import Alert 53-19 covers henna-based skin colour. FDA also states that PPD is not permitted in cosmetics applied to the skin.
EU. Henna products are cosmetics under Regulation 1223/2009: they need an EU responsible person, a safety assessment, CPNP notification and Article 19 labelling. PPD is listed in Annex III (entry 8a) only as a hair dye substance in oxidative hair dye products, with label warnings that include a reference to temporary "black henna" tattoos.
All markets. Country of origin and batch marking on every pack; see country of origin labelling.

The inspector checks that the label on each pack matches the market it is going to. A pack printed for body art must not ship on a US order for retail sale.

Packing, transit and your purchase order

Henna powder loses colour with light, heat and moisture, and cakes if it gets damp. Retail packs should be in laminated or foil pouches with good heat seals; bulk powder in lined bags; cones in sealed sleeves. The inspector checks inner liners, pouch seals, carton condition and that cartons are stacked off the floor and dry in the warehouse.

Put these in your purchase order:

Product: pure henna leaf powder, blend (with each ingredient named) or cones.
Grade: sieve mesh or fineness, colour reference and retained sample.
Lab limits: lawsone minimum, moisture, ash and acid-insoluble ash, lead and arsenic, and "PPD not detected".
Labels per market: intended use (hair or skin), warnings, ingredient list, batch code and date, country of origin.
Net weight and tolerance; pouch material and seal standard.
The lab, the tests and the number of sealed samples per lot.

Sojat is outside Jodhpur, so travel is charged at actual cost, quoted before you book; see pricing. Book an inspection near Jodhpur.

Sources

Frequently asked questions

Can henna for body art be sold in the US?

FDA has approved henna only as a hair dye. Its fact sheet says henna is not approved for direct skin application, and Import Alert 53-19 covers henna-based skin colour, so shipments can be detained. Talk to your US customs broker before ordering body-art henna.

Can an inspector detect PPD in henna?

No. PPD is found by lab analysis. The inspector draws and seals samples from the packed lot, checks that 'black' products are flagged for testing, and checks that the lab report covers the same batch codes.

What does the Sojat Mehndi GI mean for buyers?

It records Sojat, in Pali district, Rajasthan, as the origin of a registered product. It does not test quality. Your specification, the inspection and lab results still decide whether a lot is acceptable.

Is a henna and indigo blend allowed in the US?

The henna colour additive in 21 CFR 73.2190 must be free of other plant species, so a blend is not plain henna under that rule. Check the status of each ingredient with your US regulatory adviser before you order.

Do you inspect in Sojat?

Yes. Sojat is about 100 km from our Jodhpur base, so our Jodhpur inspectors cover it. Because Sojat is outside Jodhpur, travel is charged at actual cost, quoted before you book.