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EU Tattoo Ink Ban : What is ‘REACH’ and how does it impact Tattoo Artists?

A new EU regulation called REACH has brought about a ban on Blue 15:3 and Green 7 pigments, which will reduce a tattoo artist’s colours palette by 65-70%. Ink manufacturers aren’t ready for this change, and limited alternatives exist. So, what’s going to happen next?

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What does REACH stand for?

This new EU regulation on tattoo pigments stands for Registration, Evaluation, Authorisation, and Restriction of CHemicals (REACH). It is the Regulation (EC) No 1907/2006. The ban concerns Blue 15:3 and Green 7 pigments. They are only two pigments, but because they are primary and secondary colours, they will impact 65-70% of artists’ colours palettes.

What is the purpose of the EU Tattoo Ink Ban ?

The EU Tattoo Ink Ban called REACH is a preventive measure.

According to the European Agency for Safety and Health at Work, “The purpose of this regulation is to ensure a high level of protection of human health and the environment.” And when it comes to human health, in this instance, the Agency refers to a possible risk of cancer. 

Studies on tattoo inks, in general, have shown that a relatively small portion of tattoo customers have declared skin discomfort. However, they are pretty challenging to find. 

One study pointed out that 6% of participants have experienced some reaction. Tattoo allergies exist, and the level of discomfort occurs to be similar to some skin diseases such as psoriasis and eczema. However, it’s difficult to establish a direct link between tattoo pigments and increased cancer risk long-term. 

Are there any studies on the pigments in question?

No, the two pigments banned haven’t been established as toxic for humans. There has been no study to date.

Blue 15:3 is already prohibited in hair colouring treatments. The EU regulation considers that if a substance is not permitted in cosmetic products because it is not regarded as safe to apply on human skin, it is reasonable to assume that it is also not safe to be used under the skin, i.e., where the substance stays in the dermis for a prolonged time.

Is there a link between these pigments and cancer?

It’s worth noting that currently no, there is no cancer linked to tattoo pigments or inks. However, there have not been any epidemiological studies testing for a potential link between tattoo inks and cancer. And that study could take years.

European studies are underway, and we appreciate all research initiatives. It means the EU acknowledges tattoo arts and crafts, and we witness some passionate researchers who can do their best to protect the future of our industry. We can hope for a balanced position in the future where customer safety and public health meet artistic freedom and a prominent colours palette.

EU Tattoo Ink Ban – So why the concern now?

Currently, as the tattoo ink market represents only a marginal fraction of the global production of colourants, the pigments used in tattoo inks are not explicitly produced for such purposes. They may therefore contain levels of impurities that are not appropriate for human skin.

Approximately 163,000 litres of tattoo inks are estimated to be imported into the European Economic Area every year. Most manufacturers operates from the United States where the production of tattoo ink and pigments is unregulated. National agencies issue no guidelines or standards. 

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What Happens Next?

From January 2022, Tattoo artists must use only EU-compliant inks. Resellers and manufacturers will not be authorized to sell most of the actual inks under the label “tattoo inks.”

Labeling is inconsistent. Some manufacturers displays the list of ingredients when others don’t. Tattoo artists are concerned mainly by the quality of colours, and if the ink will be easy to work with and stay over time. The EU regulation could be the first step towards a more harmonious and transparent market proposal for tattoo artists and clients. However, with the lack of qualitative alternatives, artists might be forced into illegality.

There has been massive social media coverage recently on REACH within the tattoo niche. In countries such as Germany and France, media are reaching out to artists and tattoo associations to understand what is true from what’s not from what they read on social media.

The UK, Australia, and Switzerland are collecting evidence to adapt REACH to their territories.

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What’s a good ink?

Good ink is REACH compliant, goes easily into the skin, and lasts the test of time. 

It is worth noticing that to this day, 100% of inks are not compliant to REACH. It is difficult but feasible in some way to change the ink composition. Some manufacturers have share being actively testing alternatives. Given the small window of time between now and January, there is a fear that some ink manufacturers will be compliant at minimum charge.

Some manufacturers are currently only relabelling tattoo inks into artist ink. Without a qualitative alternative, artists are left with a subsequent responsibility to be regulation-compliant and out of business or legally reprehensible and keep practicing their art. Many tattoo artists already face this dilemma in Spain, where a single tattoo ink manufacturer is allowed in the territory. Therefore, tattoo artists use illegal inks to meet customers’ demands.

“Even if you forbid the content of colorants, unfortunately, many tattooers will be able to buy these and use them anyway. They will just be sold as ‘artist material’ rather than listed as tattoo inks.” 

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So, can the EU enforce the regulation properly?

Unfortunately, the EU regulation committee might not have been aware of the specific ‘artist material’ situation. Indeed, in several European Union states, restrictions on tattoo inks are already in place where they are similar or more restrictive. In these markets, alternative tattoo inks exist and are bought by tattoo artists and tattoo shops. The EU regulation committee may have concluded that an existing alternative solution is sufficient to fill the gap. 

Tattoo artists and industry leaders haven’t shared the lack of endorsed controls on inks limitation with the EU authorities. Indeed, in already heavily regulated countries, the artist displays the authorized inks and may offer them the first choice to their customers. But, it will not take long for them to switch to tattoo inks that give better results as long as their client is informed and happy to use them. 

In this situation, most artists only meet customers’ demands with whatever inks are available on the market. Most will positively welcome EU-compliant tattoo inks if they deliver similar qualitative results compared to the existing ones. 

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Are there real alternatives to blue and green pigments? 

Unfortunately, not yet. We might be years away from possible replacements, so it will take time to match the actual quality of inks.

In many ways, tattoo artists feel powerless in their ability to meet customers’ expectations and hamstrung in their everyday artistic practice.

Mario Barth, the founder of Intenze Tattoo Ink, warned in a video on the consequences of the EU-ban. “You’re talking about 65-70% of the palette that a tattoo artist uses.” he says, “It’s a matter of freedom and choice.” 

However, he said nothing on how to match the regulation exigencies. 

We fully empathise with artists and the impact these regulations will have on their color palette. As a community of artists, we understand that challenging times might be ahead, and we are working actively to limit negative consequences. We believe in informing and supporting, and we don’t consider it is our job to impose a specific type or brand of ink on any of the talented artists we are lucky to collaborate with. They are independent artists and should not be limited in their creation from the tattoo studio or the country they choose to operate in as long as we preserve the customer’s health.

We have faith in the future of our industry. And that a solution will be found which helps artists keep creating stunning tattoos made to last.

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Is there anything I can do to help?

Globally, people have been mobilized for a couple of years and engaged in active EU discussions. Save the Pigments is a call to action from Michl Dirks and Erich Mähnert to bring all tattoo artists together and raise a voice to be heard by the authorities from the EU. 

It takes a 5 to 10 minutes effort to sign the EU petition, but it is worthwhile. To this day, there are 108 944 supporters for that petition, and it is growing daily. There is significant participation in the petition. However, it will take time for the EU commission to answer back.

If you are interested in having these inks tested and want to contribute to pigment research, join the European Society of Tattoo and Pigment Research (ESPT). Their experience is unique and will help the industry.

If you want to go further on the same topic, these articles might interest you: 

Tattoo Allergy: How Do I Know If I Am Allergic To Tattoo Inks?

Tattoo Aftercare

François